U.S.

Department
Advisory
of Transportation

Federal Aviation
Circular
Administration

Subject: INSTRUCTIONS FOR Date: 11/20/07 AC No: 25.1529-1A

CONTINUED AIRWORTHINESS OF Initiated by: ANM-100
STRUCTURAL REPAIRS ON
TRANSPORT AIRPLANES

1. PURPOSE.

a. This advisory circular (AC) provides instructions to ensure the continued airworthiness
of structural repairs on certain transport category airplanes. The intent of this AC is to ensure
that damage tolerant structure will remain damage tolerant after it has been repaired. This AC
applies to transport category airplanes operating under Title 14, Code of Federal Regulations
(CFR), parts 91, 125, and 135, and to transport airplanes operating under parts 121 and 129 that
have a passenger seating capacity of less than 30 passengers and a maximum payload capacity of
less than 7,500 pounds. Instructions for ensuring the continued airworthiness of structural
repairs on transport airplanes operating under parts 121 and 129 that have a passenger seating
capacity of 30 or more, or a maximum payload capacity of 7,500 pounds or more, are provided
in AC 120-93, Damage Tolerance Inspections for Repairs and Alterations. AC 120-93 applies
to transport airplanes that are required to comply with §§ 121.1109 and 129.109.

b. This AC addresses the approval procedures to follow when making structural repairs to
structure certificated under the damage tolerance requirements of § 25.571, Amendment 25-45 or
later, and to type designs with Supplemental Inspection Documents (SIDs) which were based on
these criteria. The methods provided herein are not the only means acceptable for showing
compliance with the applicable portions of § 25.1529 and Appendix H of part 25. The Federal
Aviation Administration (FAA) will consider other methods of compliance the applicant may
elect to present.

2. APPLICABILITY.

a. The guidance provided in this document is directed to airplane manufacturers,

modifiers, civil aviation authorities, and FAA transport airplane type certification engineers and
their designees.

b. Like all advisory circular material, this AC is not, in itself, mandatory, and does not
constitute a regulation. It describes an acceptable means, but not the only means, for showing
compliance with the requirements for transport category airplanes. The FAA will consider other
11/20/07 AC 25.1529-1A

methods of demonstrating compliance that an applicant may elect to present. While these
guidelines are not mandatory, they are derived from extensive FAA and industry experience in
determining compliance with the relevant regulations. On the other hand, if we become aware of
circumstances that convince us that following this AC would not result in compliance with the
applicable regulations, we will not be bound by the terms of this AC, and we may require
additional substantiation or design changes as a basis for finding compliance.

c. This material does not change, create any additional, authorize changes in, or permit
deviations from, regulatory requirements.

3. CANCELLATION. Advisory Circular 25.1529-1, Instructions for Continued Airworthiness

of Structural Repairs on Transport Airplanes, dated 8/1/1991, is canceled.

4. RELATED DOCUMENTS.

a. Title 14, Code of Federal Regulations (14 CFR):

Section Title

1.1 Definitions and Abbreviations, General

Definitions

21.31(c) Type Design

21.50 Instructions for Continued Airworthiness and

Manufacturer’s Maintenance Manuals Having
Airworthiness Limitations Sections

25.571 Damage-Tolerance and Fatigue Evaluation of

Structure

25.1529 Instructions for Continued Airworthiness

Appendix H to Instructions for Continued Airworthiness

Part 25

43.16 Airworthiness Limitations

Appendix A to Major Alterations, Major Repairs, and Preventive

Part 43 Maintenance

b. Advisory Circulars:

(1) AC 25.571-1C, Damage Tolerance and Fatigue Evaluation of Structure, dated

4/29/98.

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(2) AC 120-93, Damage Tolerance Inspections for Repairs and Alterations, dated
11/20/07.

5. BACKGROUND. The current industry procedure for repairing structural elements is to first
classify the repair as either major or minor in accordance with the definitions set forth in § 1.1
and Appendix A to part 43. The FAA approval procedures depend on the classification of the
repair. The structure is then restored to the original certification status; either safe-life, fail-safe,
or damage tolerant, and approved in accordance with established procedures. The definitions of
major and minor have historically been subject to widely varying application by maintenance
and inspection personnel. In order to standardize the application of the term major repair, the
FAA published a list of parts and types of repairs considered major in Civil Aeronautics Manual
(CAM) 18 in 1953. This was later adopted as Appendix A to part 43. This standardized list of
major repairs has, in some cases, resulted in the classification of minor repairs as major simply
because the list has not been updated to include evolving airplane design and construction
techniques and it is not practical to tailor the list to individual airplane models. There is no
attempt in this AC to redefine the terms major or minor as defined in parts 1 and 43 of the CFR.
Rather, the intent of this AC is to ensure damage tolerant structure will remain damage tolerant
after it has been repaired.

The advent of damage tolerant design in modern transport category airplanes further
complicated the approval procedures for repairs by introducing the need for additional testing
and/or analysis in order to assess the long term effects of repairs on damage tolerant structure.
Although the repairs may be structurally sound and airworthy when completed, it is not practical
in many instances to complete the damage tolerance evaluation for long term airworthiness prior
to returning the airplane to service. This necessitates an interim repair approval where the repair
is found to be structurally sound relative to static strength but has not been analyzed for long
term airworthiness effects. The final approval of the repair is made shortly thereafter and before
long term fatigue effects are manifested. This AC provides guidance to airplane manufacturers
and to those authorized to repair structures, in cases where this two-phase approval process is
necessary.

6. DEFINITION OF TERMS.

a. Damage tolerance means that the structure has been evaluated to ensure that should
serious fatigue, corrosion, or accidental damage occur within the operational life of the
airplane, the remaining structure can withstand reasonable loads without failure or excessive
structural deformation until the damage is detected.

b. Fail-safe means the structure has been evaluated to assure that catastrophic failure is not
probable after fatigue failure or obvious partial failure of a single, principal structural
element.

c. Safe-life means that the structure has been evaluated to be able to withstand the repeated
loads of variable magnitude expected during its service life without detectable cracks.

d. Primary structure is structure that significantly contributes to the carrying of flight,

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11/20/07 AC 25.1529-1A

ground, or pressure loads. It is also known as a structurally significant item (SSI).

e. Principal structural elements (PSE) are those elements of primary structure which
contribute significantly to carrying flight, ground, and pressurization loads, and whose
failure could result in catastrophic failure of the airplane.

f. Single load path is where the applied loads are eventually distributed through a single
member, the failure of which would result in the loss of the structural capability to carry the
applied loads.

g. Multiple load path is identified with redundant structures in which (with the failure of
individual elements) the applied loads would be safely distributed to other load-carrying
members.

7. GUIDANCE. Appendix H to part 25 specifies the general requirements for the preparation
of instructions for continued airworthiness as required by § 25.1529. The following guidance is
to be used in conjunction with Appendix H and other related regulations.

a. Structural Repair Manual. The applicant should include in the maintenance instructions
required by Appendix H, paragraph H25.3 (b), a structural repair manual (SRM) which
describes the types of structural repairs anticipated in service. This SRM should be reviewed
and approved by the FAA.

b. Principal Structural Elements. The SRM should identify all PSEs and primary structure
requiring approved repair data. Examples of PSEs may be found in AC 25.571-lC, Damage
Tolerance and Fatigue Evaluation of Structure, dated 4/29/98.

c. Repair Documentation. Any repair to a PSE or primary structure, including the removal
of cracks and corrosion, requires some form of approval whether deemed "major" or "minor"
under the definition of part 1 and the provisions of part 43. The SRM should provide criteria
for determining if the repair warrants FAA engineering approval. In general, repair to a PSE
or primary structure requires FAA engineering approval. Such approval is usually
accomplished by the FAA, a designated engineering representative (DER), or Special
Federal Aviation Regulations (SFAR) 36 authorized staff.

d. Substantiating Repairs. Additionally, the SRM should provide guidance to repairers as to

what substantiating data is necessary to show that the repair complies with certification
requirements. This guidance should address repairs to PSEs and primary structure for which
no FAA-approved or acceptable data currently exists. It should identify the applicable
certification requirements and describe acceptable methods for demonstrating compliance.
The SRM must tell the repairer that FAA approval is required for such repairs.

e. Two Stage Structural Evaluation.

(1) Applicants may elect to allow two-stage repair approval in which the basic
structural evaluation shows that the repair will meet immediate and short term strength

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11/20/07 AC 25.1529-1A

requirements (ultimate strength) but a more extensive investigation is required to show

long-term strength requirements. If the applicant elects this option it must schedule the
completion of the evaluation such that the airplane is not subjected to the risk of
structural failure due to fatigue in the interim. For example, a two-stage evaluation may
be recommended where;

(i) A static structural strength evaluation is made prior to release of the airplane into
service with a stated time for completion of the damage tolerance evaluation, and

(ii) A damage tolerance evaluation of the repair is made within the prescribed time
period after this interim release. The final evaluation must reflect any changes in
the related inspection program, including the threshold, interval, and inspection
procedure.

(2) Final repair approval should not be made until a damage tolerance evaluation has
been completed and has shown that the repair is adequate to assure continued
airworthiness. The time period established for completion of the approval should be
based on technical, logistic, and recordkeeping considerations. Due to the logistics and
recordkeeping requirements and the ability of the operator to realistically track follow-
on technical approval programs, a time period for completion of the approval process
that does not exceed 12 months is generally adequate for most structural repairs. This
time period is justified based on the assumed inherent crack free performance of
structure designed to maintain its initial strength level for the lifetime of the structure.

(3) Procedures must be established by the operator as agreed upon by the manufacturer,
with approval from the cognizant aircraft certification office, which would assure timely
completion of the approval process. These procedures should also provide for audits to
ensure that interim repairs are finalized as scheduled.

f. Special Qualifications. Guidance should be provided with regard to the qualifications of

persons evaluating and approving repairs made to certain PSEs which have special design
considerations. For example, a particular design may include certain PSEs having damage
tolerant structure requiring a person who has comprehensive knowledge of the specific
design philosophy, loading spectrum, and fracture mechanics techniques used in that
particular design. Due to these qualifications of the specialist, responsibility for the
assessment may be restricted to staff members of the airframe manufacturer, certain DERs,
the FAA, or certain SFAR 36 engineering staff. The FAA aircraft certification offices
should provide guidance in regard to qualifications of personnel.

g. Logic Diagram. The logic diagram in Figure 1, below, is provided to assist in the
determination of when FAA engineering approval is required for a repair to damage tolerant
structure. The decision process begins when it has been determined that structural damage
has occurred.

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11/20/07 AC 25.1529-1A

Figure 1 - How to Determine if FAA Engineering Approval is Required

Structural
LOGIC DIAGRAM – Determination of
Damage
When FAA Engineering Approval Is
Has Occurred
Required For a Repair to Damage
Tolerant Structure

Is
Repair
There An Yes Per
Approved SRM
SRM
Procedure?

No
Is
There An Repair per
Existing FAA Yes Approved
Approved Procedure
Procedure?

No

Does Damage Yes

Affect A PSE
Item?

No

Does Repair
Affect Other Major Yes
Repair Items
CFR 1.1?

No
Repair
Does Not Repair
Require FAA Requires FAA
Approval Approval

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11/20/07 AC 25.1529-1A

The following guidance is offered for use with the logic diagram:

(1) Determine if the repair can be accomplished using standard methods defined in the
SRM for the particular airplane. These standard repair methods may be simple or
complex, for example:

(i) Blend out - local.

(ii) Replacement with identical part.
(iii) Oversize attachment.
(iv) Reduction of edge distance.

(2) For damage not covered by an SRM procedure, determine if an FAA approved
repair exists or if other means of repair acceptable to the FAA exists, for example:

(i) FAA approved repair.

(ii) Service bulletin (FAA or DER approved).
(iii) All operators letter (FAA or DER approved).
(iv) SFAR 36 repair previously approved.

(3) Once it has been determined that the damage or repair does not affect PSE, then it
must be determined whether it affects other criteria in the major repair definition of §
1.1; i.e., systems, weight and balance, aerodynamics, or airplane performance.

(4) If it has been determined that a repair must be submitted for FAA approval, and
cannot be shown to have prior approval or other acceptable data, it may be approved by
the FAA, a DER, or an SFAR 36 authority.

Signed by

Ali Bahrami
Manager, Transport Airplane Directorate
Aircraft Certification Service