Legal Aspects of Fabric Covering

in Aircraft Fabric Covering

When a fabric-covered aircraft is certificated, the aircraft manufacturer uses materials and techniques to cover the aircraft that are approved under the type certificate issued for that aircraft. The same materials and techniques must be used by maintenance personnel when replacing the aircraft fabric. Descriptions of these materials and techniques are in the manufacturer’s service manual. For example, aircraft originally manufactured with cotton fabric can only be re-covered with cotton fabric unless the Federal Aviation Administration (FAA) approves an exception. Approved exceptions for alternate fabric-covering materials and procedures are common. Since polyester fabric coverings deliver performance advantages, such as lighter weight, longer life, additional strength, and lower cost, many older aircraft originally manufactured with cotton fabric have received approved alteration authority and have been recovered with polyester fabric.

There are three ways to gain FAA approval to re-cover an aircraft with materials and processes other than those with which it was originally certificated. One is to do the work in accordance with an approved supplemental type certificate (STC). The STC must specify that it is for the particular aircraft model in question. It states in detail exactly what alternate materials must be used and what procedure(s) must be followed. Deviation from the STC data in any way renders the aircraft unairworthy. The holder of the STC typically sells the materials and the use of the STC to the person wishing to re-cover the aircraft.


The second way to gain approval to re-cover an aircraft with different materials and processes is with a field approval. A field approval is a one-time approval issued by the FAA Flight Standards District Office (FSDO) permitting the materials and procedures requested to replace those of the original manufacturer. A field approval request is made on FAA Form 337. A thorough description of the materials and processes must be submitted with proof that, when the alteration is completed, the aircraft meets or exceeds the performance parameters set forth by the original type certificate.

The third way is for a manufacturer to secure approval through the Type Certificate Data Sheet (TCDS) for a new process. For example, Piper Aircraft Co. originally covered their PA-18s in cotton. Later, they secured approval to recover their aircraft with Dacon fabric. Recovering an older PA-18 with Dacron in accordance with the TCDS would be a major repair, but not an alteration as the TCDS holder has current approval for the fabric.

Advisory Circular (AC) 43.13.1, Acceptable Methods, Techniques, and Practices—Aircraft Inspection and Repair, contains acceptable practices for covering aircraft with fabric. It is a valuable source of general and specific information on fabric and fabric repair that can be used on Form 337 to justify procedures requested for a field approval. Submitting an FAA Form 337 does not guarantee a requested field approval. The FSDO inspector considers all aspects of the procedures and their effect(s) on the aircraft for which the request is being filed. Additional data may be required for approval.

Title 14 of the Code of Federal Regulations (14 CFR) part 43, Appendix A, states which maintenance actions are considered major repairs and which actions are considered major alterations. Fabric re-covering is considered a major repair and FAA Form 337 is executed whenever an aircraft is re-covered with fabric. Appendix A also states that changing parts of an aircraft wing, tail surface, or fuselage when not listed in the aircraft specifications issued by the FAA is a major alteration. This means that replacing cotton fabric with polyester fabric is a major alteration. A properly executed FAA Form 337 also needs to be approved in order for this alteration to be legal.

FAA Form 337, which satisfies the documentation requirements for major fabric repairs and alterations, requires participation of an FAA-certificated Airframe and Powerplant (A&P) mechanic with an Inspection Authorization (IA) in the re-covering process. Often the work involved in re-covering a fabric aircraft is performed by someone else, but under the supervision of the IA (IA certification requires A&P certification). This typically means the IA inspects the aircraft structure and the re-cover job at various stages to be sure STC or field approval specifications are being followed. The signatures of the IA and the FSDO inspector are required on the approved FAA Form 337. The aircraft logbook also must be signed by the FAA-certificated A&P mechanic. It is important to contact the local FSDO before making any major repair or alteration.