Delta Air Lines REPAIR STATION MANUAL 145-10

Page 1 06/10/98

CLASSIFICATION AND SUBSTANTIATION OF ENGINEERING

AUTHORIZATIONS
TABLE OF CONTENTS PAGE
I. GENERAL ............................................................................................................. 1
II. DEFINITIONS ....................................................................................................... 2
III. PROCEDURES FOR CATEGORIZATION ................................................................. 5
IV. CLASSIFICATION GUIDELINES - ALTERATIONS, REPAIRS AND OTHER EA'S ...... 6
V. PROCEDURES FOR CLASSIFYING REVISIONS TO AN EA....................................... 8
VI. LOGIC DIAGRAMS FOR CLASSIFICATIONS .......................................................... 9
VII. LIST OF EFFECTIVE PAGES .................................................................................. 17

I. GENERAL

It is necessary to specifically identify those Engineering Authorizations (EA’s) which direct the
accomplishment of major alterations or major repairs as compared to other maintenance
actions

FAR 43.13(a) stipulates that all work performed on a civil aircraft must be accomplished using
methods, techniques and practices which are acceptable to the (FAA) Administrator, with the
exception that some maintenance operations must be performed per FAA approved data. FAR
1, 21, 43, 65, 91, 121 and 145 require, in part, that all major alterations and major repairs be
accomplished in accordance with FAA approved data. FAA policy restricts approval of major
alterations to FAA Field Approvals, Supplemental Type Certificate Approvals, Airworthiness
Directives or FAA DER Approvals by Designated Engineering Representatives (DER’s)
authorized to function in behalf of the Type Certificate Owner. Moreover, by definition, major
alterations are those which are not listed in the FAA approved Aircraft, Engine, or Appliance
Specification and meet other specified criteria. Therefore, alterations which are listed in the
applicable FAA approved specification and accomplished in accordance with manufacturer's
instructions, are minor regardless of their complexity.

This document provides procedures to be used by Delta engineering for classifying and
substantiating EA’s in compliance with FAA requirements. The first step in this process is to
determine the category of action directed by the EA. All Delta EA’s which direct work on the
aircraft or affect other documents (i.e. manuals, etc.) which influence aircraft activities, will be
categorized as alterations, repairs or other. Once the category of each EA has been established,
it is then necessary to determine the type of data required for FAA approval of the EA.
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FAR 43 appendix "A" provides examples of major alterations and repairs for all types of
aircraft. However, these lists are not all inclusive and the examples are so broad that they are
obviously not intended for literal application to modern transport aircraft. FAR 1.1 provides
the basis for a functional definition of major alterations and repairs, as well as minor
alterations and repairs. In practice, FAR 1.1 and FAR 43 appendix "A" must be reconciled
through judgment, to establish the classification of EA’s. To facilitate consistency in this
process, this document provides definitions and the logic process which will be utilized to
categorize and classify EA’s. In addition, instructions for documentation of this logic process
are provided.

II. DEFINITIONS

See FAR 1.1 for definitions in conjunction with the following:

EA’s that require classification: Engineering Orders, Engineering Repair/Authorizations,

Service Evaluations, Special Inspections and Variation Authorizations.

A. Categories

1. Alteration - A deliberate action to transform an airworthy configuration into another

airworthy configuration (i.e., a proactive effort).

2. Repair - Authorization or restoration of an aberrant or degraded condition (i.e., a

reactive effort).

3. Other - Any action that is neither an alteration nor a repair (i.e. procurement
information, correcting, adding or clarifying information in the manuals, gathering
data, etc.). This category is also used for parts provisioning, providing equivalent
build standards or test procedures, and providing part equivalence information.

B. Classifications

1. Accepted Practices - Are any practices accomplished in accordance with:

• Any process or procedure which is FAA approved

• Delta or applicable manufacturer's Component Maintenance Manual, Engine
Manual, Maintenance Manual, Overhaul Manual, Structural Repair Manual, or
Service Instructions
• Delta or applicable manufacturer's Process Standards
• FAA Advisory Circulars (e.g., 43.13-1, 43.13-2, 65-9, 65-12, and 65-15)
• Methods and guidelines provided by Delta, Manufacturer, FAA, Military,
University Course work or Industry publications for activities such as failure
mode and effect analysis, systems analysis and stress analysis.
• Military and Government handbooks or standards
• Product manufacturer's specifications
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2. Aircraft, Engine, Propeller or Appliance Specifications - Data inclusive of the

following with effectivity which extends to the specific product:

• Manufacturer's manuals, such as: Aircraft Maintenance Manuals, Component

Maintenance Manuals, Engine Manuals, Overhaul Manuals, Structural Repair
Manuals and Process Specifications
• Manufacturer's production drawings and specifications
• Manufacturer's Service Bulletins
• Type Certificate and Type Certificate Data Sheet

3. Appreciable Effects - As they relate to the definition of Major Alteration or Major

Repair are those that:

• Weight - Increase aircraft or component weight to the point of exceeding

maximum certified limits
• Balance - Alter the center of gravity to the point that the aircraft center of gravity
limits are exceeded when the aircraft is loaded in accordance with existing loading
procedures, or component imbalance limits are exceeded when all authorized
adjustments are exhausted
• Structural Strength - Alter structural elements to the point that engineering
analysis or tests, beyond the scope of accepted practices, are required to determine
the effect on structural strength, stiffness, flutter and/or damage tolerance. Major
repairs to SSI’s on B-727 and B-737 invoke AD mandated damage tolerance
evaluation and reporting requirements of SSIP.
• Performance - Alter the aircraft or powerplant configuration to the point that
thrust and/or drag variants warrant revision to the published aircraft
performance data
• Powerplant Operation - Alter the engine accessories, core engine, nacelle, or
related controls to the point that powerplant operating limits and/or powerplant
reliability are affected
• Flight Characteristics - Alter the aircraft, or powerplant to the point that aircraft
flight characteristics as reflected in the published Pilots Operating Manual,
Aircraft Operations Manual and Delta's Flight Training Syllabus are affected
• Noise - Increase noise levels to the point that certification requirements are
exceeded, except that FAR 21.93 allows periods not to exceed 90 days of
noncompliance, but otherwise airworthy, operations for maintenance purposes
• Other Airworthiness Qualities - Affect any quality of airworthiness in such a way
that there is an increased risk, in comparison to the original design, resulting from
malfunction of the altered element or improper accomplishment of the task, as it
relates to:

a. Continued safe flight and landing in any type operation for which the aircraft
is approved; or

b. Adverse affect on safety of the crew or passengers

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4. Elementary Operations - Are any operations accomplished in accordance with:

• Delta or applicable manufacturer's Component Maintenance Manual, Engine

Manual (except procedures requiring specific source substantiation), Maintenance
Manual, Overhaul Manual, Structural Repair Manual, Service Instructions, or
Standard Practice Manuals
• Delta Process Standards or Policies and Procedures manual.
• FAA Advisory Circulars (e.g. 43.13-1, 43.13-2, 65-9, 65-12, and 65-15)

5. If Improperly Done - Refers to errors that could occur during design, analysis, and/or
accomplishment that might not be detected by the responsible Engineering,
Maintenance or QA personnel, before the aircraft is returned to service. The impact
of improperly accomplished repairs, even though proper inspection techniques may be
present, should be considered; an example is a repair in a non-critical area that could
propagate into critical areas leading to catastrophic results.

6. Special Engine Repairs - Any repair involving materials and techniques not employed
during original manufacture of the part nor authorized in FAA approved documents
for subsequent repair/modification of the part. If standard procedures (Acceptable
Data) serve as the basis for demonstrating that the structural or functional integrity
of the part is not appreciably affected, then the repair is not considered to be
"Special." Under this definition, current state of the art welding, plasma spraying
(non-proprietary) or plating operations are not automatically considered Special
Repair Techniques; i.e. the process itself does not make the repair "Special"; instead,
the application of the process to a specific part makes the repair "Special" or not.

7. Structural Engine Part - External flange or any external skin of a pressure vessel,
rotating part containment structure, rotating parts, support structure and engine
mount components.

C. Supporting Data

In addition to the following technical content of substantiating data, the logic and reasoning for
the repair should be documented and understandable to all potential readers of the supporting
data.

1. Data acceptable to the administrator - Written material or documents used to describe

and/or substantiate minor alterations, minor repairs or other EAs of a minor
character, include:

• Calculations such as stress analysis and system analysis

• FAA Advisory Circulars (e.g., AC 25.1529-1, 43.13-1A, 43.13-2A and 91-56)
• FAA approved data
• Industry Publications (e.g., ASTM, SAE and University Research)
• Manufacturer's technical information (e.g., Service Bulletins, Kits, Manuals,
Service Letters, Technical Correspondence, etc.)
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• Mil Specs, Military Handbooks, Government Publications, etc., (e.g., MIL-HDBK

5, AMS, MS, NAS and SAE Specs.)
• Previously approved EA
• Published textbooks
• Recorded description of methods, techniques and practices which show compliance
with the functional requirements of the aircraft
• Technical Standard Order (TSO) data

2. FAA approved data - Written material or documents used to describe and/or approve
major alterations, major repairs or other maintenance actions requiring FAA
approval, including the following:

•
Airworthiness Directives
•
Data approved by Designated Alteration Station (DAS)
•
Data approved by Designated Engineering Representative (DER)
•
Data approved by the FAA, such as Field Approvals (i.e., 337 Forms or other)
•
Data approved through SFAR 36 Authority
•
Manufacturer's FAA approved data (when so indicated), such as Component
Maintenance Manuals, Engine Manuals, SB’s, and Structural Repair Manuals
• Supplemental Type Certificates (STCs)
NOTE: Any STC affecting Structural Significant Items (SSI’s) on B-727, B-737 airplanes will
invoke AD mandated damage tolerance evaluation requirements. Sponsoring Engineer
must assess the need for additional procedures and FAA approvals.

• Type Certificate and Type Certificate Data Sheets

• Type Design Data for certified products (i.e., mfg.’s drawings and specifications)

3. Substantiating data - Information that supports and/or describes alterations, repairs

or other EAs including, but not limited to, the following:

• Calculations and analysis

• Drawings, sketches, and/or photographs
• EAs
• Functional and operating limits
• Manufacturer's Service Bulletins, Service Letters, etc.
• Material Allowable
• Reports and other published documents

III. PROCEDURES FOR CATEGORIZATION

The only options for Delta EA categorization are: Alteration, Repair, or Other. In the case of
alterations and repairs, this category is established by the initial circumstance which motivates
the release of an EA and once established by these conditions, should not change during the
course of accomplishment. Proactive modifications to change the product from one airworthy
configuration to another airworthy configuration for purposes of function or performance
changes are alterations.
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Reactive efforts to either authorize an aberrant or degraded condition for continued service
without restoration, or to restore same to a serviceable condition are “repairs”.

Any Delta EA which does not direct or prescribe an action which falls within the above
definitions for “alteration” or “repair”, will be categorized as “other”.

These definitions are reasonably straightforward. However, logical rationality must be applied
to categorize some EAs which seemingly could fall in more than one category. For example,
Special Inspections (SIs) could be classified as "alterations", "repairs" or "other". SIs which
inspect for a condition and do not provide instructions for response are classified as “other”.
SIs which inspect for a configuration which is acceptable for continued service (i.e. Airworthy),
but for purposes of standardization, etc., are modified upon discovery, are “alterations”.
Conversely, SIs which inspect for discrepancies and provide damage limits for continued
operations or restoration instructions are “repairs”.

EAs which revise Delta's manuals will be categorized based on the direct effect they cause on
the configuration of the aircraft. For example, EAs which provision parts but rely upon other
EAs to authorize use of the part, would be categorized as “other”. Whereas, EAs which
provide both authorization for use, and advance provisioning for repair parts would be
categorized as “alterations”, “repairs” or “other”. EAs which provide alternate or equivalent
standard parts which are utilized as part of routine maintenance, but do not alter the function
or operating limits of the assembly or installation, are categorized as “other”.

EAs which provide alternate or equivalent build standards or test procedures, for components
in overhaul, but do not alter function or operating limits, are categorized as “other”.

The category must be clearly noted on the title sheet of the initial release in the location
specified. The engineer who authors an engineering release and the approval designee(s) are
responsible for this categorization and since it requires the judgment of these people to
establish a conclusion, changes may occur during the EA approval process. Notwithstanding
this, once a consensus has been reached to classify the initial EA release as an “alteration” or a
“repair”, changes to the accomplishment instructions precipitated by events or circumstance
which become evident during the accomplishment phase, should not change this categorization.
EAs which are initially categorized as "other" may conceivably be converted to an Alteration
or a Repair following their initial release.

IV. CLASSIFICATION GUIDELINES - ALTERATIONS, REPAIRS AND OTHER EA'S.

Due to differences in logic, and documentation required for each category of EA, this section is
separated into classification guidelines appropriate to alterations, repairs and other EAs. Refer
to section VI for the Logic Diagrams referenced below.

A. Alterations

• The logic diagram shown in Figure 1 shall be used as a checklist for the considerations
required to determine whether an aircraft alteration is major or minor.
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• The logic diagram shown in Figure 2 shall be used as a checklist for the considerations
required to determine whether a powerplant alteration is major or minor.
• The logic diagram shown in Figure 3 shall be used as a checklist for the considerations
required to determine whether an appliance alteration is major or minor.
• The logic diagram shown in Figure 4 shall be used as a checklist for the considerations
required to determine whether a software alteration is major or minor.

B. Repairs

• The logic diagram shown in Figure 5 shall be used as a checklist for the considerations
required to determine whether an airframe repair is major or minor.
• The logic diagram shown in Figure 6 shall be used as a checklist for the considerations
required to determine whether an engine repair is major or minor.
• The logic diagram shown in Figure 7 shall be used as a checklist for the considerations
required to determine whether an appliance repair is major or minor.

C. Other

The category of "other" has been created by Delta, as a convenience for identifying EAs which
do not authorize the accomplishment of alterations or repairs. Nonetheless, all actions performed
on the aircraft must be accomplished in accordance with either "Data Acceptable to the
Administrator" or "FAA Approved Data", as appropriate. Therefore, to avoid confusion and
conflict with FARs which define specific actions predicated on the classification of "Major" for
"Alterations" and/or "Repairs", EAs categorized as “other” will not be classified as major or
minor. Instead, EAs categorized as “other” will be evaluated via the logic process depicted in
Figure 8 to reveal the type of data required to support release of the EAs. The conclusion will
be identified by an entry in the FAA APPROVAL field of the EA title block as follows:

• “Not Applicable" (N/A), implying that no aircraft actions are involved and therefore
FAA participation is not required, or
• "FAR 145.51b", or "A Document Identifier" (e.g. Service Bulletin #, TWX #, etc.)
implying that "Data Acceptable to the Administrator " is required and available, or
• "A Document Identifier" (e.g. Service Bulletin #, TWX #, 8110-3, etc.), depicting that
document which provides FAA approval.

One of these classifications will be clearly noted on the title sheet for each Alteration, Repair or
Other EA. The rationality for this classification is to be confirmed by the appropriate approval
designee(s). Since it requires the judgment of these people to establish a conclusion, changes to
the classification may occur during the EA approval process. In addition, changes to the
classification of an EA which do not affect the accomplishment or scheduling instructions, may
occur without formal revision to the EA, prior to its approval release and/or distribution of the
approved EA. A copy of the checklist with the appropriate logic path noted, along with
substantiating data, as appropriate, is to be provided for each released EA.
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V. PROCEDURES FOR CLASSIFYING REVISIONS TO AN EA

EA classification is that which is specified on the title page. Moreover, the EA title sheet must
reflect the highest order of data required to support the EA (i.e. "FAA approved data" is
higher than "data acceptable to the administrator"). Therefore, any EA that has a revision
which requires "FAA Approved Data" must reveal this fact on the title page. Notwithstanding
this, a revision or Variation Authorization (VA) will be judged only in regard to the need for
authority other than that for the initial release. Revisions to an EA which are judged to be
minor deviations from the original EA will be supported by "data acceptable to the
Administrator"; whereas, revisions which go beyond the scope of the original approval and this
action is classified as major, must be specifically authorized by "FAA approved data."

A. Alteration and Repair - Alterations are premeditated acts to change one airworthy
configuration to another airworthy configuration. Therefore, it is unlikely that the initial
classification of an "alteration" will be changed by circumstance which become evident
during the accomplishment phase. On the other hand, the classification of repairs
frequently change as a result of circumstance which were not evident during the initial
reporting and/or circumstance which occur during their accomplishment. Revisions
which are judged to be minor deviations from the original EA will be supported by "data
acceptable to the Administrator" which will be indicated by placing "FAR 145.51b" or the
document identifier in the appropriate revision footnote field. In other words, no
additional FAA approval is required for the subject revision. EAs with a classification of
major, can have minor revisions. Nonetheless, substantiation for this position (i.e. Data
acceptable to the administrator) should be provided, as appropriate, and filed with the
EA. Should the revision go beyond the scope of the original substantiation, specific FAA
approval must be obtained for the revision. This will be indicated by placing the
identification of the FAA approval document in the appropriate revision footnote block,
and if the EA was previously classified as minor, changing the title page classification to
MAJOR. In this event, the revision footnote and the substantiating data must clearly
demonstrate the chronology and rationality of the EA evolution.

B. Other - EAs categorized as “other” which require FAA Approved Data, must identify the
document which provides subject approval in the FAA APPROVAL field of the EA title
page. Therefore, an EA categorized as “other” which has a revision that requires FAA
Approved Data, must note that fact by identification of the approved data in the FAA
APPROVAL field on the Title page. Notwithstanding this, EAs which require FAA
approval for the initial release can, as appropriate, have minor revisions which will be
reflected by placing "FAR 145.51b" or the document identifier which provides "data
acceptable to the Administrator" in the appropriate revision footnote field.
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VI. LOGIC DIAGRAMS FOR CLASSIFICATIONS:

Figure 1 - Aircraft Alterations

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Figure 2 - Powerplant Alterations

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Figure 3 - Appliance Alterations

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Figure 4 - Software Alteration

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Figure 5 - Airframe Repair

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Figure 6 - Engine Repairs (Includes Mounts & Engine Related Structure)

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Figure 7 - Appliance Repair

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Figure 8 - Other
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VII. LIST OF EFFECTIVE PAGES

APPROVED: (signed original on file in D.509)

TITLE: Director - Quality

ACCEPTED: (signed original on file in D.509) DATE: (dated original on file in D.509)
TITLE: FAA CMO-27

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