AD/A320/180 Amdt 2 - Fuel Tank Decals

The AD relies on several key concepts drawn from airworthiness regulation and maintenance practice.

Airworthiness Directive (AD): A mandatory legislative instrument issued under the Civil Aviation Regulations that requires specific action to address an unsafe condition in an aircraft type. Non‑compliance renders the aircraft unairworthy and may ground it.

Applicability: The Directive applies only to the serial numbers (MSN) explicitly listed. It does not apply to all A319‑100 or A320‑200 aircraft. The list in the table contains 179 MSNs, plus a note that aircraft incorporating SB A320‑28‑1149 (any revision) are excluded. This narrow list captures only those aircraft originally manufactured with the problematic decals. Amendment 2 removed several MSNs after the manufacturer confirmed they were never marked with such labels. The operator must check whether the aircraft’s MSN appears in the table and whether it has the relevant service bulletin incorporated.

Minimum Equipment List (MEL) and Master Minimum Equipment List (MMEL): The MMEL is the regulatory baseline for dispatch with inoperative equipment. The AD mandates insertion of a Temporary Revision (TR) to the MMEL that prohibits flight with one pump inoperative. This is an operational limitation: the aircraft cannot be dispatched with a failed pump unless both pumps on the same side are operative. Note 1 indicates this TR will be incorporated into the next general MMEL revision.

Service Bulletin (SB): Manufacturer‑issued instructions for inspections, modifications, or repairs. The AD references three Airbus service bulletins: SB A320‑28‑1102 (fuel pump and canister inspection), SB A320‑57‑1117 (fuel tank inspection), and SB A320‑28‑1149 (fuel strainer installation). Each must be accomplished using the specified revision or later DGAC‑approved revision. “DGAC” refers to the French Direction Générale de l’Aviation Civile, the original type‑certificate authority for the Airbus A320 family. The AD recognises earlier revisions of some SBs as providing partial compliance (e.g., SB A320‑28‑1102 Revision 1 satisfies Requirement 3, and SB A320‑57‑1117 Revision 1 satisfies Requirement 5 for initial compliance but not for subsequent repetitive inspections).

Terminating Action: Requirement 6, the installation of new fuel strainers per SB A320‑28‑1149, is described as “terminating action from the inspection requirements of this AD.” That means once the strainers are installed, the repetitive fuel tank inspections (Requirement 4) no longer apply. The strainers likely prevent label debris from reaching the pumps, thus rendering the inspections unnecessary. This concept is important for compliance planning: operators that complete Requirement 6 permanently reduce their ongoing compliance burden from 600‑ or 3,000‑hourly inspections to a one‑time modification.

Compliance times: The AD specifies distinct times for each requirement. Requirement 1: within 10 days from effective date. Requirement 2: before further flight after a pump failure (but note the MEL prohibition may already prevent dispatch). Requirement 3: within 600 flight hours from effective date. Requirement 4: repetitive intervals based on SB incorporation status. Requirements 5 and 6: calendar times (30 July 2011 or 162 months from entry into service). The mix of hours‑based and calendar‑based deadlines creates a need for careful tracking.

Repetitive inspection vs terminating action: The AD structures compliance as a series of escalating steps: immediate operational limitation, reactive pump inspection, proactive pump inspection, fuel tank inspection at recurring intervals, and finally a one‑time modification that ends the recurrence. Operators that fail to perform the terminating action face indefinite repetitive inspections.

The primary duty‑holders are the owners and operators of the 179 specific Airbus A319‑100 and A320‑200 aircraft identified by serial number (MSN) in the applicability table. Only aircraft on that list are subject to the AD. The operator is the person or organisation responsible for the aircraft’s continuing airworthiness under Civil Aviation Regulation 42ZC or equivalent. That entity must plan and fund the required inspections, parts, and labour.

Maintenance organisations , both Part 145‑approved and other licensed engineers , will perform the physical tasks. They must have access to the correct revision of each Airbus service bulletin and the approved data for any deviation. The AD does not require CASA approval for each inspection if the service bulletin is followed exactly, but any alternative method of compliance would require prior CASA approval (a standard condition in all ADs).

Aircraft manufacturers (Airbus) and the French DGAC are indirectly affected: the AD mandates their service bulletins and revisions. The AD also refers to EASA AD 2006‑0236R1, showing coordination with European regulatory action.

CASA is the enforcing authority. The Directive was signed by a CASA Delegate on 23 April 2007 and became effective 30 April 2007. CASA will monitor compliance through maintenance records, audits, and inspection reports. Non‑compliance can lead to enforcement actions including grounding, suspension of airworthiness certificates, and civil penalties.

Less directly, the AD affects insurers, financiers, and lessors of the aircraft. A lease agreement typically requires the lessee to maintain airworthiness and comply with all applicable ADs. Failure to do so could constitute a default. The AD’s compliance deadlines (especially the 162‑month limit for certain MSNs and the 30 July 2011 date) create absolute calendar bars that may require the aircraft to be taken out of service if not met.

The AD also affects the residual value of affected aircraft. An aircraft that has not incorporated the terminating action (Requirement 6) carries a future compliance burden that a buyer would need to factor into purchase price. Conversely, aircraft that are not on the applicability list (those never built with the labels or those with SB A320‑28‑1149 already installed) are unaffected and may be more attractive.

There is a concentration of compliance burden on a relatively small number of aircraft worldwide (179 MSNs, plus the original broader applicability from Amendment 1). The cost per aircraft is moderate: pump inspections (labour), tank inspections (labour, possible tank entry), and strainer parts. But the opportunity cost of downtime for inspection and modification could be substantial for high‑utilisation operators. The 10‑day deadline for MEL insertion is a low‑cost administrative step, but the 600‑hour deadline for pump inspection may come sooner for high‑utilisation aircraft.

Duty to insert MMEL TR (Requirement 1): Within 10 days of the effective date (30 April 2007), the operator must insert the specified Temporary Revision into the aircraft’s MEL. This effectively imposes an operational limitation: the aircraft cannot be dispatched with one fuel pump inoperative. This duty is immediate and does not depend on the aircraft’s flight hour state.

Duty to inspect after pump failure (Requirement 2): If a fuel pump fails after the effective date, before further flight the operator must inspect the failed pump, the other pump in the same half‑wing, and both canisters per SB A320‑28‑1102 Revision 2 or later. Rectification must be accomplished as instructed. This duty is reactive and event‑driven.

Duty to inspect all pumps (Requirement 3): Within 600 flight hours from the effective date, all four wing pumps and canisters must be inspected per the same service bulletin. If the aircraft already incorporates SB A320‑28‑1102 Revision 1, that satisfies this requirement (but not the subsequent repetitive ones).

Duty to perform repetitive tank inspections (Requirement 4): The AD imposes repetitive fuel tank inspections per SB A320‑57‑1117 Revision 2 or later. The interval is 600 flight hours for aircraft that have not incorporated that SB at Revision 1 or later; 3,000 flight hours for those that have incorporated at least Revision 1. The operator must choose which path to take. Note this is an ongoing duty until terminating action is accomplished.

Duty to perform initial tank inspection and strainer installation (Requirements 5 and 6): By a calendar deadline (30 July 2011 for most MSNs; 162 months from first entry into service for MSNs 982, 1051, 1083), the fuel tanks must be inspected per SB A320‑57‑1117 Rev 2 and new fuel strainers installed per SB A320‑28‑1149. Requirement 6 is the terminating action; once done, Requirement 4 stops.

Rights of the operator: The operator has the right to use later DGAC‑approved revisions of any service bulletin. This provides flexibility if the manufacturer issues updates. The operator also has the right to seek CASA approval for alternative methods of compliance, though the AD does not explicitly state this (it is standard under regulation 42ZA or equivalent). The operator may also choose to incorporate SB A320‑28‑1149 earlier than the deadline to stop the repetitive inspections sooner, which could reduce long‑term maintenance costs.

Rights of the regulator: CASA may inspect records, require evidence of compliance, and take enforcement action. The AD is a legislative instrument; contravention can attract penalties under the Civil Aviation Act 1988. The delegate who signed the AD (David Punshon) acted under delegated authority.

No duty to perform additional SB incorporation: The AD only mandates the service bulletins listed. It does not require incorporation of any later revisions of non‑referenced bulletins. However, if Airbus issues a later revision of SB A320‑28‑1102 that is DGAC‑approved, the operator may use it as an alternative.

The AD itself does not state specific penalties; those arise from the parent regulations under which it is made. Non‑compliance with an airworthiness directive is an offence under Civil Aviation Regulation 42K (or equivalent). Penalties can include fines, suspension or cancellation of the airworthiness certificate, and grounding of the aircraft. The Civil Aviation Act 1988 (s 20AB) provides for civil penalties of up to 1,000 penalty units for individuals and 5,000 for body corporates, with a penalty unit currently around $222. Depending on the nature of the breach, criminal prosecution is also possible if the non‑compliance was reckless or knowing.

Enforcement is the responsibility of CASA. CASA may issue a direction to ground the aircraft until compliance is achieved. The AD’s compliance times are not mere suggestions: Requirement 1 within 10 days, Requirement 2 before further flight, Requirement 3 within 600 flight hours, etc. Failure to meet any deadline renders the aircraft unairworthy under regulation 42A, and any flight in that state could incur additional penalties for operating an unairworthy aircraft.

Practically, enforcement will often occur through maintenance records. Maintenance organisations must certify that the AD is complied with in the aircraft logbook or maintenance release. CASA auditors will check these records during routine surveillance. For operators of multiple aircraft, a systematic failure to track AD compliance can lead to suspension of the Air Operator’s Certificate.

The AD also interacts with the EASA AD (2006‑0236R1). While not directly enforceable by EASA in Australia, a failure to comply with the Australian AD could affect the aircraft’s acceptance in other jurisdictions if the European AD is also not complied with. This creates an extra‑jurisdictional enforcement risk for operators who intend to fly the aircraft overseas.

The AD provides no grace period for repetitive inspections beyond the stated intervals. Overdue inspections would need to be done before further flight. The date‑based deadlines (30 July 2011, 162 months) are absolute; there is no extension mechanism within the AD itself, though CASA could in theory issue a variation or grant an exemption under reg 11 of the Civil Aviation Regulations.

Economic penalties from non‑compliance also include indirect costs: loss of aircraft utilisation, reputational damage, increased insurance premiums, and potential lease default. These can far exceed the direct statutory penalties.

The AD is made under the Civil Aviation Regulations 1988 (Cth), specifically regulation 42K or a similar provision empowering CASA to issue mandatory continuing airworthiness requirements. It sits within the broader regulatory framework for aircraft airworthiness in Australia: the Civil Aviation Act 1988, the Civil Aviation Regulations 1988 (CAR 1988), and the Civil Aviation Safety Regulations 1998 (CASR 1998). For older aircraft, CAR 1988 still applies. The AD uses the form of an “Airworthiness Directive” and is a legislative instrument within the meaning of the Legislation Act 2003, though it may not be registered on the Federal Register of Legislation (many ADs are not, but are published on the CASA website).

The AD explicitly references the EASA AD 2006‑0236R1 (Note 2). This shows coordination between CASA and the European Aviation Safety Agency. Australia is not an EASA member state, but the AD shows a reliance on the same service information as the EASA AD. Operators with EASA‑registered aircraft would need to comply with both ADs; the Australian AD is a separate legal requirement for aircraft on the Australian register.

The AD also interacts with the Maintenance Control Manual requirements under CAR 1988 regulation 42ZE. An operator must have procedures to ensure AD compliance and record keeping.

The AD does not explicitly interact with Part 145 maintenance approvals, but the service bulletins referenced may contain tasks that require the maintenance organisation to hold appropriate ratings. The AD does not specify any additional training requirements; it relies on existing licensing.

There is potential interaction with the Civil Aviation (Offences) Regulations 2023 for penalty enforcement. The AD itself is not an offence regulation, but non‑compliance is an offence under the parent regulation.

The AD may also interact with the Personal Property Securities Act 2009 if the aircraft is financed; a failure to maintain AD compliance could affect the asset’s value.

There is no mention of the Work Health and Safety Act 2011, but fuel tank entry is a confined space operation that would trigger state or territory WHS requirements.

The AD does not address privacy, competition, or other commercial laws. Its effect is purely technical and safety‑related.

The original issue of AD/A320/180 became effective on 20 July 2005. It addressed the floating‑label issue by mandating an operational limitation (MEL insertion), repetitive fuel pump inspections, and repetitive fuel tank inspections. That original AD applied to an initial set of MSNs.

Amendment 1 became effective on 15 March 2007 (published in the source as “9 March 2007” for the EASA AD, but the Australian AD effective date for Amdt 1 is stated as 15 March 2007). Amendment 1 enlarged the applicability to include MSN 982, 1051, and 1083. It also updated references to service bulletin revisions (likely to include later revisions that had been released) and mandated the installation of new fuel strainers per SB A320‑28‑1149, which provided terminating action to the repetitive inspections. This was a significant structural change: it transformed the AD from a purely inspection‑based regime into one that had a definite end point through modification.

Amendment 2, the current version, became effective on 30 April 2007. The background states: “Amendment 2 removes from the applicability those aircraft which were found not to be originally marked with the labels concerned by this AD.” This means the earlier applicability was over‑broad; some aircraft that were listed never had the specific decals. The amendment narrows the list, relieving those owners from the compliance burden. The amendment also makes reference to the latest revision status of the service documents (the AD now references SB A320‑28‑1102 Revision 2 and SB A320‑57‑1117 Revision 2), and it notes that aircraft incorporating SB A320‑28‑1149 are excluded from applicability altogether. The AD as amended takes a more targeted approach.

The amendment also updates the note about EASA AD: the original issue of the Australian AD likely referenced EASA AD 2006‑0236 original; Amendment 2 now references EASA AD 2006‑0236R1 dated 9 March 2007, and states that this AD supersedes EASA AD 2006‑0236 original issue. This alignment ensures that both regulators require essentially the same actions.

The amendment did not change the compliance times of Requirements 1‑4 (except possibly for the new MSNs it added, which now have the 162‑month deadline for Requirements 5 and 6). It did not alter the effective date of the original AD for existing MSNs.

This amendment history shows that CASA was responsive to manufacturer feedback: once Airbus confirmed that certain aircraft never had the labels, CASA removed them. This is a positive example of regulatory burden reduction when new facts emerge. However, the operator of an MSN that was removed must still ensure that it does not inadvertently have the labels; the removal is based on manufacturer records, not a waiver of responsibility.

There is no recorded litigation specifically concerning AD/A320/180 Amdt 2 in Australian courts. Airworthiness directives are generally not the subject of judicial review because they are legislative instruments with limited scope for challenge. An operator could theoretically seek judicial review under the Administrative Decisions (Judicial Review) Act 1977 on grounds of jurisdictional error or unreasonableness, but such challenges are rare in the airworthiness context. The cost of challenging an AD usually outweighs the cost of compliance.

The more likely arena for litigation is contractual: lease disputes where a lessee fails to comply with the AD and the lessor claims breach. There may have been such disputes in commercial aviation, but they are not publicly reported or specific to this AD.

CASA has internal review processes for AD compliance disputes. If an operator believes the AD does not apply to its aircraft, it can seek a determination from CASA. If CASA refuses, that decision could be reviewed. No such case is known.

The AD is based on an EASA AD, and there have been enforcement actions by EASA member states for non‑compliance with the underlying European AD. Some of those may have led to administrative penalties, but not to reported court decisions.

The absence of litigation does not mean the AD is uncontroversial. The original applicability was over‑broad, and Amendment 2 corrected that. If an operator had grounded an aircraft incurring costs based on the original applicability, and then the AD was amended to remove that MSN, the operator might have a claim for compensation from CASA under the Australian Constitution (s 51(xxxi)) for acquisition of property on unjust terms. However, no such claim appears to have been made. The amendment was a correction, not an acquisition.

The litigation history for this AD is essentially nil. That is typical for airworthiness directives. They are technical, narrow, and generally complied with. The cost of challenging them far exceeds the cost of compliance, and the regulator has broad discretion.

Several aspects of this AD can catch out the unwary operator or maintenance organisation.

Applicability is not all A319/A320s: The AD applies only to a list of 179 specific MSNs. An operator of an A320 not on that list might mistakenly believe it is subject to the AD and perform unnecessary work, or worse, fail to do work if its MSN should be on the list (but the list is exhaustive, so if not listed there is no obligation). However, the original applicability (before Amendment 2) was broader, so older maintenance records may still show the AD as applicable. Operators must check the current AD text and ensure their records reflect Amendment 2.

Aircraft incorporating SB A320‑28‑1149 are excluded: The AD states “This AD is not applicable to the aircraft incorporating Airbus Service Bulletin (SB) A320‑28‑1149 at any Revision status.” That means if the aircraft already has the new strainer design, it is outside the AD entirely. Operators that have incorporated that SB should confirm their records and remove the AD from their compliance list.

Compliance times start from effective date, not service bulletin date: The 10‑day and 600‑hour deadlines run from 30 April 2007, not from the date the service bulletin was released or from the date of the last inspection. This is critical for aircraft that were already in service at effective date.

Requirement 2 applies before further flight after any pump failure: The operator must act immediately if a pump fails, even if the failure occurs years later. The AD does not expire. Any pump failure on an affected aircraft triggers Requirement 2.

Repetitive inspection interval depends on SB incorporation status: Aircraft that have not incorporated SB A320‑57‑1117 Revision 1 or later must inspect every 600 flight hours; those that have incorporated Revision 1 get 3,000 hours. The operator can save maintenance costs by incorporating the earlier revision, but must do so before the 600‑hour threshold if they want the longer interval. Note that simply having Revision 1 is sufficient for the longer interval; Revision 2 is not required.

The 162‑month clock runs from first entry into service: For MSNs 982, 1051, and 1083, Requirement 5 and 6 must be complied with within 162 months from when the aircraft first entered service, not from the AD effective date. The operator must know the aircraft’s first service date to calculate the deadline. If that date is earlier than the effective date, the deadline may already have passed. For those aircraft, the AD likely required immediate compliance upon Amendment 1.

Terminating action only stops Requirement 4: After installing new fuel strainers (Requirement 6), the repetitive tank inspections of Requirement 4 end. But the pump inspection of Requirement 2 (reactive) and Requirement 3 (one‑time) are already completed; there is no further AD requirement. However, the MEL TR from Requirement 1 may remain in effect until superseded by the next MMEL revision. The operator should confirm with the MMEL revision.

The AD references DGAC‑approved revisions: If Airbus releases a later revision of a service bulletin, it must be DGAC‑approved for use under the AD. An operator cannot simply adopt any later revision; they must verify DGAC approval. This may require checking the EASA or French authority’s website.

Note 1 about next MMEL revision: The temporary revision to the MMEL will be incorporated into the next general MMEL revision. Once that happens, the requirement to have a separate TR may fall away, but the operator must check when that occurs. The AD does not give a date.

Potential confusion with EASA AD: Note 2 says this AD supersedes EASA AD 2006‑0236 original issue. If an operator holds both an Australian and an EASA registration for the same aircraft, they must ensure compliance with the Australian AD; the EASA AD is superseded, but EASA may have its own later amendment (the reference is to R1). Operators should check current EASA AD status separately.

No grace for 600‑hour deadline: The 600 flight hours run continuously. If the aircraft is grounded for other reasons, the clock still runs during flight. The operator cannot delay inspection by parking the aircraft.

Compliance with AD/A320/180 Amdt 2 requires a structured plan that integrates into the operator’s continued airworthiness management system. The steps below assume the aircraft is on the applicability list and does not already have SB A320‑28‑1149. If the aircraft does have that SB, the AD does not apply; record that fact in the compliance status.

Step 1: Confirm applicability and effective date. Check the aircraft MSN against the 179 listed numbers. If the MSN is listed, the AD applies as of 30 April 2007. If the aircraft also has SB A320‑28‑1149 incorporated, it is excluded. Verify incorporation status and record why the AD is not applicable if appropriate.

Step 2: Insert MMEL TR within 10 days (by 10 May 2007). Locate the MMEL for the aircraft type. Insert Temporary Revision No 01‑28/01Z issue 01 (the one referenced by the AD). The TR prohibits flight with one pump inoperative. Ensure the flight crew is briefed and the MEL is updated. Record the insertion in the aircraft logbook or equivalent. This step should be completed immediately if the AD was not actioned earlier.

Step 3: Schedule pump and canister inspection within 600 flight hours. Arrange for a licensed maintenance organisation (LAME) to perform Requirement 3 inspection per Airbus SB A320‑28‑1102 Revision 2 (or later DGAC‑approved revision). The inspection covers all four wing pumps and their canisters. If the aircraft already incorporates Revision 1 of that SB, Requirement 3 is considered compliant; record that and move to Step 4. If not, the inspection must be done within 600 FH of 30 April 2007. Plan for possible part replacement or rectification per the SB. Document findings.

Step 4: Establish repetitive fuel tank inspection program. Determine the applicable interval based on SB A320‑57‑1117 incorporation status:

• If the aircraft has not incorporated any revision of SB A320‑57‑1117, the initial inspection (Requirement 5) must be done by 30 July 2011 (or earlier if flight hours accumulate quickly), and then repeat every 600 FH until terminating action.
• If the aircraft has incorporated Revision 1 or 2 (or later DGAC‑approved revision), the repetitive interval is 3,000 FH. The initial inspection deadline remains the same.

Step 5: Plan for terminating action (Requirement 6). Procure the new fuel strainers per Airbus SB A320‑28‑1149 original issue or later DGAC‑approved revision. Install them by 30 July 2011 (or 162 months from first entry into service for the three specified MSNs). This modification ends the repetitive inspection requirement. Confirm installation in the aircraft logbook and stamp the AD as having terminating action accomplished.

Step 6: Update the AD compliance schedule. After Requirement 6 is accomplished, the AD is fully complied with. However, the operator should ensure that the MMEL TR is still in effect (it may be superseded by a general MMEL revision). Check with the MEL provider.

Step 7: Handle pump failures reactively. If a fuel pump fails at any time after effective date, before further flight comply with Requirement 2: inspect the failed pump, the companion pump, and both canisters per SB A320‑28‑1102 Rev 2, and rectify per instructions. This applies even after terminating action, because the AD does not remove Requirement 2; only Requirement 4 stops. However, after terminating action, a pump failure may not generate label‑related debris, but the AD still requires the inspection. The likely interpretation is that the inspection is to check for label ingestion; if the labels are removed by the strainer, the risk is lower, but the AD text does not exempt Requirement 2 after terminating action. Therefore, operators should still comply.

Step 8: Maintain records. For each compliance action, record the date, flight hours (where applicable), service bulletin revision used, findings, rectifications, and person certifying. Keep these records accessible for CASA audit.

Cost considerations: The major cost items are: labour for pump inspection (approx 4‑8 hours), labour for tank inspection (10‑20 hours, includes tank entry), strainer parts (moderate cost), potential pump or canister replacements if damage found, and aircraft downtime. The terminating action may require a dedicated maintenance input. The repetitive inspection regime favours early incorporation of SB A320‑57‑1117 to get the 3,000‑hour interval, and early installation of strainers to end inspections altogether. The operator should perform a cost‑benefit analysis: if the aircraft is near the 30 July 2011 deadline, performing the strainer installation early may reduce ongoing inspection costs. If the aircraft has many MSNs, a fleet‑wide approach may be more efficient.

Compliance verification: Use an AD compliance matrix tracking each requirement, completion date, and next due date (for repetitive items). After terminating action, mark the AD as closed. Any future maintenance actions related to pump failure should still reference this AD.

Finally, note that this AD is now over 17 years old. Many aircraft subject to it will already have the strainer installed. The primary risk now is for aircraft that have not yet accomplished terminating action and are still subject to repetitive inspections. For those, immediate scheduling of Requirement 6 is prudent.