FAA-approved technical data is engineering information the Federal Aviation Administration has formally reviewed and sanctioned for use on a specific aircraft or product line. The recognized forms are Type Certificates, Supplemental Type Certificates, Parts Manufacturer Approvals, Technical Standard Order Authorizations, Airworthiness Directives, field approvals recorded on FAA Form 337, and Designated Engineering Representative findings recorded on FAA Form 8110-3.1Federal Aviation Administration. Inspect a Maintenance Provider’s Technical Data – FAA Order 8900.1, Vol. 6, Ch. 14, Sec. 1 You need approved data any time the work is classified as a major repair or major alteration; without it, the aircraft cannot legally be returned to service.
Approved Data Is Not the Same as Acceptable Data
This distinction trips up experienced mechanics. The two categories are not interchangeable, and using the wrong one for the wrong job can ground an aircraft or trigger enforcement action.
Approved data is information the FAA has formally reviewed and sanctioned. It covers the design approvals issued under 14 CFR Part 21, along with data individually approved through field approvals, DER findings, and Airworthiness Directives.1Federal Aviation Administration. Inspect a Maintenance Provider’s Technical Data – FAA Order 8900.1, Vol. 6, Ch. 14, Sec. 1
Acceptable data covers the methods, techniques, and practices found in manufacturer maintenance manuals, Instructions for Continued Airworthiness, and similar sources the FAA considers adequate for routine work. Under 14 CFR 43.13, anyone performing maintenance must use the methods in the current manufacturer’s manual or “other methods, techniques, and practices acceptable to the Administrator.”2eCFR. 14 CFR 43.13 – Performance Rules (General) Advisory Circular 43.13-1B is the classic example. It provides acceptable repair techniques for nonpressurized structures when no manufacturer instructions exist, and it works fine for minor repairs.3Federal Aviation Administration. Acceptable Methods, Techniques, and Practices – Aircraft Inspection and Repair (AC 43.13-1B) It does not automatically qualify as approved data for major work.
Here is where people get into trouble. A manufacturer’s service bulletin, a “No Technical Objection” letter, or a statement that a repair is “DER approvable” does not, by itself, constitute FAA approval. If the work is classified as major, you must secure one of the recognized forms of approved data before the aircraft goes back into service. Changes to previously approved data also require fresh FAA approval, because modifying approved data renders it unapproved regardless of how minor the change seems.4Federal Aviation Administration. AC 120-77A – Performance Rules: Provisions Contained in an Operator Manual Under 43.13(c)
When Approved Data Is Required
Whether you need approved data depends entirely on whether the FAA classifies the work as major or minor. Federal regulations define a major repair as one that, if done improperly, could appreciably affect weight, balance, structural strength, performance, powerplant operation, or flight characteristics. A major alteration follows the same logic: if the change could meaningfully affect those qualities, or if it is not listed in the aircraft’s type certificate data sheet, it is classified as major.5eCFR. 14 CFR 1.1 – General Definitions A minor repair or alteration is anything that falls outside those criteria.
Appendix A to 14 CFR Part 43 spells out specific examples. On the airframe side, major work includes changes to wings, tail surfaces, fuselage, engine mounts, control systems, landing gear, and the basic design of fuel, electrical, hydraulic, or pressurization systems. Powerplant major alterations include converting an engine to a different approved model, substituting structural engine parts with unapproved replacements, and switching to a different fuel grade. For propellers, changes to blade design, hub design, or governor systems all qualify as major.6eCFR. Appendix A to Part 43 – Major Alterations, Major Repairs, and Preventive Maintenance
The classification dictates your paperwork. Minor repairs can be performed using acceptable data from manufacturer manuals or advisory circulars and recorded in the aircraft’s maintenance logbooks. Major repairs and alterations require approved data, must be documented on FAA Form 337, and a copy of that form must be sent to the FAA Aircraft Registration Branch in Oklahoma City within 48 hours of returning the aircraft to service.7eCFR. 14 CFR Part 43 – Maintenance, Preventive Maintenance, Rebuilding, and Alteration
Design Approvals Under 14 CFR Part 21
The most common sources of approved data come from the manufacturing certification process under 14 CFR Part 21. These approvals cover entire product lines rather than individual aircraft, so the same data can support maintenance across a fleet.8eCFR. 14 CFR Part 21 – Certification Procedures for Products and Articles
- A Type Certificate is the original design approval for an aircraft, engine, or propeller. It confirms the product meets all applicable airworthiness standards and includes the type design, operating limitations, and the certificate data sheet.
- A Supplemental Type Certificate is required when someone introduces a major design change to an already-certificated product. If you hold the TC, you can amend it or obtain an STC. If you do not hold the TC, an STC is your only option.
- A Technical Standard Order Authorization sets minimum performance standards for specific articles installed on civil aircraft, such as avionics, seat belts, or fire extinguishers. An article manufactured under a TSOA is considered an approved article for regulatory purposes.9eCFR. 14 CFR Part 21 Subpart O – Technical Standard Order Approvals
- A Parts Manufacturer Approval allows a manufacturer to produce replacement parts for installation on type-certificated products. PMA applicants must provide drawings, specifications, and test data demonstrating the part meets applicable airworthiness requirements, and must maintain an FAA-approved quality system.10eCFR. 14 CFR Part 21 Subpart K – Parts Manufacturer Approvals
When you install an STC kit or a PMA part following the holder’s instructions, the data backing that installation is already approved. That removes the need to seek individual FAA review for each aircraft.
Airworthiness Directives
Airworthiness Directives occupy a unique space. They are legally enforceable rules issued under 14 CFR Part 39 whenever the FAA identifies an unsafe condition in an aircraft, engine, propeller, or appliance.11eCFR. 14 CFR Part 39 – Airworthiness Directives The corrective actions spelled out in an AD automatically qualify as approved data for the work they require, and the AD’s instructions supersede conflicting guidance in standard maintenance manuals.
Service Bulletins Are Not Approved Data
Manufacturers frequently issue service bulletins recommending inspections, modifications, or part replacements. If you operate under 14 CFR Part 91, a service bulletin is advisory and compliance is voluntary unless the FAA incorporates it into an Airworthiness Directive.12Federal Aviation Administration. Service Bulletins and the Aircraft Owner Even when a manufacturer labels a bulletin “Mandatory” or “Alert” in red letters, that label alone does not create a legal obligation. Only an AD referencing the bulletin makes compliance enforceable and elevates the bulletin’s technical instructions to approved data status.
Field Approvals for a Single Aircraft
When no fleet-wide approval like an STC exists for the work you need, a field approval lets you get data approved for a single aircraft identified by its N-number. This path is common for older aircraft, unusual modifications, and one-off jobs where developing a full STC would be prohibitively expensive.
The process centers on FAA Form 337. You or your mechanic prepare the engineering data, submit it with the form, and an FAA Aviation Safety Inspector reviews the package. The inspector may evaluate the data on paper alone or conduct a physical inspection of the aircraft.
Item 3 of Form 337 is reserved for FAA use. When an inspector signs this block, the signature indicates the data has been reviewed and approved for the aircraft described on the form. One detail surprises people: the signature in Item 3 approves the data only. It does not by itself constitute approval for returning the aircraft to service. That return-to-service signoff is a separate step handled under the maintenance recording requirements of Part 43.13Federal Aviation Administration. AC 43.9-1G – FAA Form 337
A field approval becomes a permanent part of the aircraft’s records and travels with it through any future sale. Because the approval is tied to a specific tail number, it cannot be transferred to a different aircraft even if the modification is identical.
DER and ODA Approvals
The FAA cannot personally review every piece of engineering data that crosses its desk, so it delegates authority to qualified private individuals and organizations.
A Designated Engineering Representative is a private engineer appointed under 14 CFR 183.29 to approve technical data on the FAA’s behalf. DERs are specialists, and the regulation establishes separate categories including structural, powerplant, systems and equipment, radio, engine, propeller, flight analyst, flight test, and acoustical.14eCFR. 14 CFR 183.29 – Designated Engineering Representatives Each DER can only approve data within their appointed discipline. A structural DER cannot sign off on avionics data.
When a DER approves technical data, the finding is recorded on FAA Form 8110-3, Statement of Compliance With Airworthiness Standards. This form carries the same weight as data approved by the FAA’s own engineers, and commercial operators frequently use DERs because the turnaround is faster than routing everything through the FAA directly.
There is an important limitation. A DER’s authority extends only to approving the engineering data itself. The DER does not approve the physical installation. If a DER’s delegation does not include compliance inspection authority, the Form 8110-3 must include a note stating that a separate compliance inspection by the FAA is still required.15Federal Aviation Administration. Designated Engineering Representative (DER) Handbook – Order 8110.37F Someone with the proper authority still needs to verify the work was performed correctly before the aircraft flies again.
Large manufacturers and repair organizations can receive an Organization Designation Authorization, which allows the company to approve certain repairs, alterations, and technical data without routing each individual case through the FAA. An ODA holder documents its approvals on FAA Form 8100-9, which serves the same function as a DER’s Form 8110-3 at the organizational level.1Federal Aviation Administration. Inspect a Maintenance Provider’s Technical Data – FAA Order 8900.1, Vol. 6, Ch. 14, Sec. 1
Keeping Approved Data Records
Approved data is only useful if you can prove it exists when someone asks. Under 14 CFR 91.417, records of maintenance, preventive maintenance, and alterations must be kept until the work is repeated, superseded by other work, or for one year after it is performed, whichever comes later. For major alterations the retention requirement is more demanding: copies of Form 337 for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances must be retained and transferred with the aircraft when it is sold.16eCFR. 14 CFR 91.417 – Maintenance Records
Missing Form 337 records are one of the most common problems during aircraft sales. If a buyer’s pre-purchase inspection reveals a major alteration with no supporting Form 337, the alteration is essentially undocumented, and proving the aircraft is airworthy becomes the seller’s problem. Keeping your 337s organized and accessible directly affects your aircraft’s resale value and legal status.