What is a "Major" Repair?

by Brent Stockwell

Balloon repairmen, excuse me, Aviation Repair Specialists have long argued the difference between a "major" and a "minor" repair. We balloon people are not the only aircraft maintenance persons concerned. Airplane mechanics, long before the advent of the new, modern sport of hot air ballooning, tried to get a definition from the Federal Aviation Administration.

Federal Aviation Regulation Part 1 defines a Major Repair as; "a repair-(1) That, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or (2) That is not done according to accepted practices or cannot be done by elementary operations."

Let’s examine the definition.
If improperly done is the first key to interpreting this regulation. If properly done, the repair is not a major repair. If the repair does not affect weight, balance, structural strength, performance, flight characteristics, or other qualities affecting airworthiness. Part 1 does not define "improperly done", "flight characteristics", or "other qualities".

The second sentence of the definition defines a major repair as one which is "not done according to accepted practices." For example, if a repair person were to apply a patch to envelope fabric using a raw seam where a felled seam is called for by the balloon manufacturer, the repair has become a "major repair" even though it}s a small, simple, patch.

The last part of the definition defines a major repair as one that "cannot be done by elementary operations". That may be interpreted as eliminating all balloon envelope repairs as all fabric repairs are elementary.

To translate this into real-world meaning, my definition of a major repair is one which has appreciably affected:

The total weight of the balloon;
The structural strength of the balloon;
The performance of the balloon;
The flight characteristics of the balloon; or
The repair did not conform to accepted practices

To further explore this definition, let’s use as an example the replacement of a small area of an AX-7 ripstop balloon mouth with Nomex because the owner has burned it. The repair will change the weight of the balloon by about eight ounces which is less than one quarter of one percent (.25%) of the total weight of the envelope; not an appreciable increase in weight. The structural strength was not significantly changed. The performance was not changed. The flight characteristics were not changed. The replacement was done in accordance with accepted practices. There for this is a minor repair.

In fact, almost all balloon repairs are minor if compared to repairing a jet engine, or electronic instrument, or computer thingamabob. Balloons are easy to inspect and simple to repair.

For Certificated Repair Stations (CRS), the distinction between a major and minor repair is less significant than for independent repair personnel, since, according to FAR Part 43 Appendix B(b)(1)-(4), a major repair made by a CRS may be recorded on the customer’s work order provided it is kept for two years by the CRS.

In the case of a CRS, a Form 337 is not required if a proper Work Order is completed and filed for two years.

Unfortunately, many FAA maintenance inspectors are not familiar enough with the regulations to make fine distinctions, so it behooves us to have a clear understanding of pertinent regulations and to study them often.