Q&A – Cosmetic Refinishing, Maintenance & Release

Q: Can you perform cosmetic spot repairs during our stay?
A: Yes. Cosmetic spot repairs can be performed during your stay provided the work is purely cosmetic, non-functional and outside the scope of maintenance.

Q: What do you mean by “purely cosmetic”?
A: Work that is visual only and does not affect airworthiness, structure, systems or functional performance.
Examples include colour harmonisation, blending, touch-ups and cosmetic correction of minor wear.

Q: Is this considered maintenance?
A: No. Cosmetic appearance correction is not maintenance as long as it is not part of a maintenance event or work package and has no airworthiness impact.

Q: Can this work be done independently?
A: Yes. Cosmetic appearance correction may be performed independently when it is outside maintenance and no release to service is required or implied.

Q: Do you issue a certificate or release after the work?
A: No. I do not issue a Certificate of Release to Service (CRS/RTS).
Instead, I provide a Cosmetic Work Statement describing exactly what was done.

Q: What documentation do you provide?

A: 

• A Cosmetic Work Statement stating: cosmetic appearance correction only – no maintenance – no release implied
• Traceability of materials and products used
• A clear description of the visual work performed

This documentation is not a maintenance record.

Q: When would a Part-145 organisation be required?
A:
A Part-145 organisation is required if:

• the work is part of a maintenance event or work package;
• the work is functional rather than cosmetic;
• the work is required for airworthiness or for issuing a CRS;
• a formal release or certification is expected.

Q: Can you still work in that case?
A: Yes, but only as a subcontractor under Part-145 oversight, with the release issued by the Part-145 organisation.

Q: Can this work be done while maintenance is taking place nearby?
A: Yes, physical presence during maintenance is not an issue, as long as the cosmetic work is administratively and contractually outside the maintenance scope.

Q: How do you ensure compliance?
A: By clearly limiting the scope to cosmetic appearance only, avoiding functional claims, issuing no release, and documenting all work transparently with a cosmetic work statement and traceability.