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CHAPTER 26

Modifications and Repairs

1. Introduction

1.1 CAR M states that a person or organisation repairing an aircraft or component should
assess the damage against published approved repair data and the action to be taken if
the damage is beyond the limits or outside the scope of such data. The modifications
and repairs are carried out using data approved by the DGCA or by an approved CAR
21/EASA Part 21/FAA Part 21 Design organization, as appropriate.

1.2 AAC 1 /2017 stipulates the procedure to be adopted by the owners/operators for
approval for carrying out modification and/or repair on an Indian registered aircraft,
aircraft component and item of equipment of that aircraft.

1.3 This chapter stipulates the guidelines and procedure to be followed by DGCA officers
for processing such cases for grant of approvals of major modification / repair on all
aircraft for which Type Certificates have been issued/accepted by the DGCA.

2. References

a) AAC 1/2017
b) CAR M
c) Rule 52 of aircraft Rule 1937
d) Annex 6
e) ICAO Doc 9760

3. Definition

Repair: The restoration of an aeronautical product to an airworthy condition to

ensure that the aircraft continues to comply with the design aspects of the
airworthiness requirements used for the issuance of a Type Certificate for
respective aircraft type after it has been damaged or subjected to wear.

Major Repair. Any repair of an aeronautical product that might appreciably affect the
structural strength, performance, power plant, operation flight characteristics or
other qualities affecting airworthiness or environmental characteristics of an
aeronautical product.

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Minor Repair. A repair other than a major repair.

Modification. A modification to an aeronautical product means a change to the type

design which is not a repair.

Major Modification. A major modification means a type design change not listed in
the aircraft, aircraft engine or propeller specifications that might appreciably affect
the mass and balance limits, structural strength, performance, power plant
operation, flight characteristics or other qualities affecting airworthiness or
environmental characteristics, or that will be embodied in the product according to
non-standard practices.
Minor Modification. A modification other than a major modification.

Note. The term “alteration” is also used instead of modification. These terms,
wherever used are intended to be synonymous.

4. Approval of modification and repair.

4.1 Minor modification approved by appropriately CAR 21 / EASA 21 / FAR 21 approved

design organization may be accomplished by the Approved Maintenance
Organization following documented procedures approved by Regional Airworthiness
Office .

4.2 A repair which has been classified as minor has negligible effect on the airworthiness
of the affected aeronautical product. The accomplishment of minor repairs normally
involves use of standard or generally accepted practices. Repairs that are classified as
Minor and approved by appropriately CAR 21/ EASA 21/ FAR 21 approved design
organization may be accomplished by the Approved Maintenance Organization
following documented procedures approved by Regional Airworthiness Office.

4.3 Procedures for accomplishment of modification / repair shall be established by

operator / maintenance organisation and documented in CAME / MOE. The regional
offices shall review the procedure and approve, if found satisfactory.

4.4 RAO / SRAO shall ensure that accomplishment of minor modification / repair are
intimated by the operator / AMO to local Airworthiness Office. It shall be ensured
that monthly engineering statistics report submitted by operator contains details of
minor modification / repair accomplished on the operator fleet.

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4.3 Examination of Application for Major modification / repair

4.3.1 The nominated officer at the regional airworthiness office shall examine the
application received from the owner/operator, as per CA Form -2 (MR) given in AAC
1 / 2017, for approval of major modification/repair.

4.3.2 The application shall be examined to ensure that:

a) The description of the proposed modification or repair correctly and accurately

describes the modification or repair;
b) Documents are complete and if not, advice applicant what additional
information is needed;
c) The applicant has conducted and submitted an acceptable conformity
evaluation statement that ensures the proposed modification or repair will not
impact the airworthiness of the aircraft including mass and balance and other
technical aspects such as noise level.
d) There is proof that the modification or repair is compatible with previously
approved modification or repairs;
e) The proposed modification or repair has no unsafe features;
f) The applicant has met the requirements for the provision documentation as
stipulated in the AAC 1 / 2017.

5. Procedure for approval of Major Modifications and Repairs

5.1 The regional airworthiness office shall examine the cases in two categories as follows:

a) Modifications and repairs for which Modification/Repair data has been prepared
by the aircraft, component or equipment manufacturer and approved by State of
Design and certified by Authorized Representatives (AR)/Designated Engineering
representatives (DER) of the State of Design of the aircraft.

b) Modifications and repairs for which Modification/Repair data prepared by the

owner/operator without any approval/certification from State of
Design/Authorised Representatives (AR)/Designated Engineering representatives
(DER) of the State of Design of the aircraft.

5.2 All cases where design data approved by organizations holding DOA approval from
State of Design or their designated representatives are not available, the Regional
Airworthiness Office will examine the proposal and forward the same to the
Airworthiness Directorate at DGCA Headquarters. The Airworthiness Directorate at
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DGCA Headquarters will review the case and forward the same for detailed analysis
and approval of the modification/repair scheme data to the Aircraft Engineering
Directorate (AED). The operator/owner may have to provide necessary data to AED in
line with requirements stipulated in Part-3 of AED Hand Book of Procedures
(available on DGCA website at www.dgca.gov.in). On receipt of approval from the
AED, the same shall be conveyed to the Regional Airworthiness Office for grant of
approval to owner/operator.

5.3 All cases where design data for the intended modification/repair approved by
organizations holding DOA approval from the State of Design or their designated
representatives are available, the Regional Airworthiness Office will examine the
proposal and if satisfied that all the applicable documents are submitted and the
proposal is acceptable, may permit to carry out the modification/repair on the basis
of the repair proposal and the design data.

5.4 In case an aircraft is grounded awaiting approved repair data from the DOA of state
of design and the data is received by the operator / owner on Saturdays / Sundays,
the regional airworthiness office may permit the operator / owner to submit the
proposal through email. On being satisfied that all the applicable documents are
submitted and the proposal is acceptable, the RAO /SRAO may permit to carry out
the modification/repair on the basis of the repair proposal and the design data
through email.

5.5 The formal approval shall be granted on FORM CA-2(MR) to the owner/operator by
RAO, after ensuring the following:

a) Modification/Repair has been completed as per the approved data.

b) If there are any deviations during the practical implementation of the

Modification/ Repair, they are duly authenticated by the manufacturer/
organisation holding DOA approval of the state of design.

c) The modification/repair completion report has been accepted by the DOA /

manufacturer.

d) The accomplishment of major repair/modification should be verified/

accepted by the Regional Airworthiness Office (RAO)

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5.6 Approval of major modifications / Repair at Regional Airworthiness Office shall be granted
by an officer not below the rank of DDAW.

5.7 Check list for processing of application is given as an Annexure.

6. Compatibility of Modifications And Repairs

6.1 While assessing the requests for approval of modification or repair it is required to ensure
that it is compatible with all other design changes installed on that aircraft. Modifications or
repairs designed separately may conflict or interfere with each other, despite having been
individually analysed, tested and shown to comply with all applicable standards of
airworthiness. Interaction between different modifications or repairs may be of a physical,
aerodynamic, structural or fatigue strength, electromagnetic or any other nature. Such
interaction may jeopardize the airworthiness of the aircraft. An example of potential
incompatibility would be a repair installed in close proximity to an existing repair. While the
two repairs individually may be completely satisfactory if separately installed on an aircraft
with no other design changes in the vicinity, the combination in close proximity may
introduce additional stress concentrations which cause fatigue cracks to occur after a period
of time in service. The Authority approving the repair scheme may survey the aircraft to be
repaired to establish whether there are any other design changes in the vicinity which may
interfere. In the case of an existing repair in close proximity to the new damage, it may be
necessary to remove the old repair and install a new repair encompassing both damage
areas, designed in a manner to reduce any stress concentrations to a level that will not
produce fatigue cracking.

6.2 In a more general situation, modifications may be separately designed for the same basic
aircraft type by different organizations with no knowledge of the other’s work. The
modifications may be shown separately to comply with all applicable airworthiness
standards; however, on attempting to install them on the same aircraft, it may be found that
they physically interfere with each other. Alternatively, no problems may be encountered
with the installations, but it may be found in service that the combination causes
aerodynamic buffeting, stability or control problems, fatigue cracking, structural failure,
electromagnetic interference, or any number of other problems. If the concurrent
installations of different modifications are not rigorously assessed for compatibility, there
exists the possibility that in combination they may cause serious airworthiness hazards..

6.3 Modifications and repairs design may be prepared by the same organization that
operates the aircraft into which they are incorporated. In the more general case,
however, the organization that designs and obtains design approval for the
modification or repair, the operator of the aircraft, and the organization that
incorporate the design change on the aircraft may all be different. Their separate
responsibilities are discussed below.

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6.4 Responsibilities of Holders of Approvals

6.4.1 In the case of a design change intended as a unique installation on a single aircraft,
the aircraft records and the aircraft itself should be surveyed to identify all other
design changes to the aircraft which may in any way interfere with the proposed
installation. All such existing installations should be considered in the analysis and
testing conducted to demonstrate compliance with the standards of airworthiness.

6.4.2 In the more general case where a design change is intended to be sold to many
aircraft operators and incorporated on multiple aircraft, it may not be feasible for the
designer of the modification or repair to obtain knowledge of the modification status
of every aircraft affected. The designer should account for the effects of any potential
incompatibilities between the proposed design change and any known existing or
reasonably foreseeable modifications or repairs when conducting analyses and tests
to demonstrate compliance with the standards of airworthiness and obtain design
approval. Alternatively, limitations may be placed on the design change, explicitly
advising potential users that it has not been cleared for compatibility with other
modifications or repairs and that the installer should obtain separate design approval
for installation in combination with those others.

6.4.3 The holder of a design change approval has a responsibility to assist the DGCA to
correct airworthiness deficiencies discovered in service which relate to the design
change. If, during the course of investigating a perceived unsafe condition related to
the design change, the approval holder determines that the unsafe condition results
from an incompatibility between the design and another modification or repair, the
approval holder should notify the DGCA immediately and recommend corrective
measures. If the DGCA determines that the design change must be altered to prevent
the unsafe condition from occurring in other aircraft on which it is installed, it will
normally require the approval holder to develop the corrections and issue
instructions for the installer. These instructions should provide corrective measures
for existing installations and revisions to the installation instructions for future
installations.

6.5 Responsibilities of Installers

6.5.1 Because the holder of a design approval for a particular modification or repair cannot
be expected to be aware and to have conducted analyses and tests for all the
possible design changes installed on all aircraft of a given type, the installer has a
responsibility to verify compatibility with other modifications and repairs before
installing any design change. The installer should survey the aircraft records and the
aircraft itself to determine what other design changes exist on the aircraft. Any
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questions of incompatibility with other modifications or repairs arising from the

survey should be referred for resolution to the operator.

6.6 Responsibilities of Operators

6.6.1 Operators have the overall responsibility to ensure the compatibility of all design
changes incorporated in their aircraft. The operator contracting with an installer for
incorporation of any aircraft modification or repair should provide the installer with
information on all existing design changes to the aircraft so that compatibility may be
verified. Any questions of design change incompatibility which may arise during
installation or in service should be thoroughly investigated by DGCA in association
with the approval holder. In case of any incompatibility between modifications or
repairs, the problem must be corrected. In addition to correction of the problem on
the aircraft on which it is established, it is necessary that any incompatibilities
between modifications or repairs be addressed on all other affected aircraft. The
operator should promptly report any design change incompatibilities detected during
installation or in service to the approval holder to the installer and to DGCA.

7. Oversight

7.1 RAO / SRAO shall carryout periodic surveillance to ensure that documented
procedures for approval of modifications and repair are being followed and all the
modifications / repair accomplished by the operator without formal approval by
DGCA are classified as minor by appropriately approved DOA.

8. Record Keeping

The DAW (Region) and DAW (Hqrs) will establish a system to maintain records of
all documents generated and received. It may be ensured that all related records
are maintained in chronological manner and all the pages are appropriately
numbered. Traceability of all records should be ensured for future reference.

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ANNEXURE

Note: While filling up the following checklist, either SAT or UNSAT Column to be filled up,
in case of any item of inspection is UNSAT, then the reason to be mentioned in the
remarks column.

CHECKLIST FOR APPROVAL OF MAJOR MODIFICATION/REPAIR

S.No. ITEM OF INSPECTION SAT UNSAT REMARKS

1. Check the Application Form CA 2(MR) received
is duly filled up with all relevant information.
2. Check classification of modification/repair as
minor or major either by DGCA on appropriately
approved DOA.
3. Check detailed description of the proposed
modification or repair submitted.
4. Check that the master documentation list
detailing the individual drawings and
specifications which define the modification or
repair submitted.
5. Check that all relevant documents bear
modification/repair reference number, title,
issue number and date.
6. Check all drawings and instructions necessary
for incorporation of the modification or repair
submitted.
7. Check that copy of Repair and Deviation Record
(RDR) &/or Repair Design Approval Sheet
(RDAS), as applicable, is attached along with the
repair data.
8. Check that modification/repair data has been
received from organization holding Design
Organization Approval by State of Design.
9. Check that data is certified by Authorized
Representatives (AR)/ Designated Engineering
representatives (DER) of the State of Design of
the aircraft.
Note: AR/DER shall be a regular employee of the
organization holding DOA approval.
Certifications by independent representative
shall not be acceptable.
10. Check that the applicant has conducted and
submitted an acceptable conformity evaluation
statement that ensures that the proposed

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modification or repair will not impact the

airworthiness of the aircraft.
11. Check that a proof is submitted that the
modification or repair is compatible with
previously approved modification or repairs.
12. Check that a statement is submitted that
proposed modification or repair has no unsafe
features.
13. Check
1 detailed design standards, to ensure that
the
0 operator has considered all applicable
design requirements and acceptance
engineering reports, including expected test
results to be used in determining the
compliance of the modified or repaired product.
14. Check whether any test or inspection is required
to be conducted during the progress or after the
completion of the modification/repair. Such
tests/inspection may include but are not limited
to flammability, noise requirements, EMI,
Electrical load check etc. Check the results of
such tests, as applicable.
15. Check,
1 if applicable, the record of the change in
electrical
3 load when the modification or repair is
performed in the aircraft.
16. Check,
1 if applicable, Ground check done on the
aircraft.
4
17. Check,
1 if applicable, whether Test flight is
required,
5 if so check the test flight report and
observation.
18. Check
1 any significant changing the weight and
centre
6 of gravity position of the aircraft. Also
check
a. Whether weight of aircraft is required;
b. Whether weight and balance computation
has been done;
c. Whether weight schedule has been
amended;
d. Whether after revision of weight schedule
Load & Trim sheet has been amended, if
applicable.
19. Check,
1 whether amendments of particulars in
the
7 Certificate of Airworthiness or associated
documents have been done, if applicable.
20. Check,
1 if required, whether amendments on the
following
8 have been done:
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a. Maintenance program
b. Maintenance manual
c. Repair manual
d. Parts manual
e. Wiring Diagram
f. Inspection schedule
g. MEL
h. Any other affected Maintenance data
21. Check,
1 if required, whether amendments are
done
9 to data specified in the AFM and /or Flight
crew operating manual.
22. Physical inspection of repair/modification
carried out, if considered necessary.

DISCREPANCIES/ DEFICIENCIES:

S.No. DISCREPANCY/ DEFICIENCY REMARKS

NOTE: Cases where design data is not approved by organisations holding DOA from State
of Design or their designated representatives, refer Checklist given as appendix-III in
Part-3 of AED Hand Book of Procedures to be evaluated by AED.

Recommended/Not recommended Signature:

Signature:
Name & Designation:
Date:

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