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3.2.1.4  Modifications and repairs may be designed 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 installs the design change on the aircraft may all be different. The operator’s and installer’s separate responsibilities are discussed below.
3.2.2 Responsibilities of installers
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 some responsibility to verify compatibility with other modifications and repairs before installing any design change. As stated in the following paragraph, the ultimate responsibility remains on the operator. The installer should survey the aircraft records and the aircraft itself to determine what other design changes exist on the aircraft. Any questions of incompatibility with other modifications or repairs arising from the survey should be referred for resolution to the operator.
3.2.3 Responsibilities of operators
3.2.3.1 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 consultation with the approval authority or approval holder, or by an independent engineering organization. In every case of incompatibility between modifications or repairs, the problem must be corrected and it must be established to the satisfaction of the authority of the State of Registry that the modified aircraft continues to comply with the applicable standards of airworthiness.
3.2.3.2 In addition to correction of the problem on the aircraft on which it is discovered, 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 its own airworthiness authority.
3.3 Retention of modification and repair data and records
3.3.1. Introduction
3.3.1.1 Annex 6, Part I, 8.6 and Part III, Section II, 6.6 state:
“All modifications and repairs shall comply with airworthiness requirements acceptable to the State of Registry. Procedures shall be established to ensure that the substantiating data supporting compliance with the airworthiness requirements are retained.”
Annex 6, Part I, 8.4.1 and Part III, Section II, 6.4 state: “An operator shall ensure that the following records are kept for the periods mentioned in
[8.4.2 for the aeroplane and in 6.4.2 for the helicopter]:
…
c)  appropriate details of modifications and repairs”.
3.3.1.2 The objective of this section is to provide guidance to aircraft operators by setting out acceptable procedures for the retention of modification and repair data and records. (The corresponding guidance for the maintenance organizations which perform modification and repairs should be found in the Chapter 4 of Part IV of this Manual)
3.3.1.3  Modifications and repairs may be designed by the operator of the aircraft into which they are incorporated. In such a case, the responsible airworthiness authority would normally issue the design approval to the operator. In the more general case, however, the holder of the design approval and the aircraft operator may be different. Annex 6 places responsibility for the retention of modification and repair data and records on both the approval holder and the operator. In the case where the aircraft operator is also the design holder, the operator must retain both sets of records. (See Part III, Chapters 5 and 6 for the design holder responsibilities regarding the retention of modification/repairs data).
　
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