AD/A330/112 - State of Design Airworthiness Directives

This Directive rests on a small set of interlocking administrative concepts that determine who must do what and by when.

• State of Design Airworthiness Directives by reference. The Directive requires operators to consult and, where applicable, implement DGAC ADs listed in Table 1. The instrument therefore functions as an incorporation by reference mechanism: CASA does not rewrite the DGAC ADs; it requires Australian operators to adopt their requirements where applicable. The Requirement wording is procedural: determine applicability, then perform required actions where not previously accomplished (Requirement 1 and 2).

• Applicability and once-only ADs. The Directive identifies the captured instruments as once-only actions, and notes that many have compliance dates that already passed under the DGAC issuances (Background). The Table lists numerous DGAC AD numbers and titles such as “Main Landing Gear - Doors” (1998-268-073(B) R3), “Doors - Slide Locking Mechanism” (1998-484-081(B) R2), through to later items like “Fuselage - Reinforcement” (2002-528(B)). Because these ADs were originally time-limited or required within specific periods, CASA’s Directive restores a compliance obligation for aircraft that entered Australian registries after the DGAC compliance windows closed.

• Record and certification timing. The compliance provision draws a distinction between non-certificated aircraft and certificated aircraft. For non-certificated aeroplanes the actions must be completed prior to issue of the airworthiness certificate. For certificated aeroplanes the deadline is within 30 days after the Directive’s effective date (Compliance). This ties the AD to the Australian airworthiness certification process by conditioning issuance of a certificate on completion where the aircraft is newly registered and not yet certificated.

• Delegated issuance. The document is signed by a CASA delegate, Mike Higgins, dated 8 April 2010, and indicates an effective date of 30 April 2010. The AD is therefore an administrative directive issued by CASA under its delegated powers, rather than primary legislation.

• Access to State of Design ADs. The directive supplies two internet addresses where the DGAC ADs may be accessed (Note 1). The ADs themselves contain the technical measures (inspections, modifications, part replacements). CASA’s Directive does not replicate technical instructions, but mandates their application where applicable.

• Non-applicability caveat. The Background expressly acknowledges that some of the DGAC ADs will not be applicable to some aeroplanes because of date of manufacture, or configuration and modification status. Practically, this places an evidentiary burden on the operator to determine and document non-applicability rather than to obtain a blanket exemption.

Together these concepts create a compliance architecture where CASA re-imposes State of Design requirements on a domestic operator population that may have acquired affected airframes after the original DGAC compliance windows closed. The Directive’s mode is quick, directive and incorporationary: identify, consult, implement, and certify completion within short timeframes.

The Directive names applicability as “All A330 series aeroplanes.” That wording makes the class of affected parties straightforward in the narrow sense: any person or entity responsible for the continuing airworthiness and operation of Australian-registered Airbus A330 series aeroplanes. Concretely that group will include the following stakeholders.

• Registered owners and operators of A330 series aeroplanes. Owners and operators are the primary parties who must determine applicability of the listed DGAC ADs and, where applicable, perform the required actions. For aircraft already certificated in Australia the work must be done within 30 days of the Directive’s effective date (Compliance). For aircraft not yet certificated, the actions must be completed before the certificate of airworthiness may be issued.

• Maintenance organisations and certificated maintenance engineers. The actions required by the DGAC ADs will frequently be technical inspections, modifications or part replacements that require maintenance organisation capability and a release to service. Maintenance providers are therefore operationally implicated: they must carry out the DGAC-mandated work or provide technical assessments of non-applicability relating to configuration or modification status.

• Registrars and airworthiness certification staff. Staff responsible for issuance of certificates of airworthiness are affected in that the Directive sets a pre-condition for certificate issue where an aircraft has not yet been certificated: the listed actions must be completed first (Compliance). This imposes a gatekeeping obligation on whoever controls certificate issuance.

• Importers and brokers of recently manufactured or imported A330s. CASA’s Background explains that the DGAC ADs have compliance dates that have passed, and that CASA determined these ADs may be applicable to recently-registered Australian aircraft. That line pulls importers and brokers into scope where they are dealing with aircraft that entered the Australian register after the original DGAC compliance windows closed.

• Airworthiness managers and compliance officers. The Directive requires determination and recordation of applicability. Organisations with continuing airworthiness responsibilities will need to update their compliance registers, maintenance programmes and record-keeping to reflect either completion or a documented non-applicability rationale.

Who pays. The Directive does not allocate financial support or compensation. The natural reading is that operators and owners bear the cost of determining applicability and performing the required actions where those actions are applicable and not previously completed. Those costs may range from administrative time to technical inspections, modifications, replacement parts, maintenance labour and potential downtime while work is carried out.

Who decides. The Directive places the initial decision point on the aircraft operator or responsible person to determine whether each DGAC AD applies to the specific aeroplane (Requirement 1). If the operator determines applicability and the work has not already been done, the operator must implement the DGAC AD actions (Requirement 2). Where there is doubt about applicability, the Directive does not provide a prescriptive appeal or alternative compliance mechanism within its text; the operator will need to document its decision and execute the required work or otherwise evidence non-applicability.

Behavioural change. Affected parties must review configuration records, historical maintenance and modification records, and the DGAC ADs themselves. Operators who acquired aircraft after the DGAC compliance windows may need to retrospectively implement modifications or inspections that otherwise would have been completed earlier under the state-of-design regime. Maintenance scheduling, certificate issue timing and budget forecasting may need to be adjusted to accommodate potentially substantial once-only actions.

The Directive creates operative duties but does not enumerate rights in the way a statute might. The duties are set out directly in the Requirement and Compliance text; rights must be inferred only from the absence of contrary provisions.

Primary duties

• Determine applicability. Duty to determine whether each DGAC AD listed in Table 1 applies to the specific aeroplane is an affirmative, immediate duty (Requirement 1). This requires review of the DGAC AD texts, the aeroplane’s configuration, serial numbers, parts and modification status.

• Perform required actions where applicable and not previously accomplished. This is an obligation to carry out the technical steps specified in each relevant DGAC AD if the AD applies and its actions have not been previously completed (Requirement 2).

• Meet the timing conditions. For aircraft without a certificate of airworthiness, compliance must be achieved before the certificate is issued; for certificated aircraft, compliance must occur within 30 days of the Directive’s effective date (Compliance).

• Record retention and evidencing compliance. While the Directive does not stipulate an evidence regime, the operator will need to be able to demonstrate that they have determined applicability and performed required actions where applicable. The Background expressly contemplates that some ADs will not be applicable because of configuration or manufacture date; that places an implicit duty to document why a particular DGAC AD is not applicable.

Duties not in the text

• The Directive does not specify alternative methods of compliance, delegations of compliance, exemptions, or administrative review processes. It does not identify a specific CASA contact for questions in the body of the text, nor does it specify the form of evidence operators must retain.

Rights and procedural points

• Right to rely on evidence of previous accomplishment. The Requirement 2 framing indicates that operators who can show a listed DGAC AD “has been previously accomplished” need not repeat the action; the Directive therefore recognises the factual defence of prior compliance.

• Implied right to determine non-applicability. The Background’s explicit recognition that some ADs will not be applicable implies that operators may lawfully determine non-applicability on the basis of manufacture date, configuration or modification status. The operator’s burden is to document that determination.

• Access to source ADs. The Directive provides URLs where DGAC ADs can be accessed (Note 1). That is a practical right to consult the instrument that CASA has required to be implemented.

Administrative decision-maker

• The Directive was issued by a CASA delegate, Mike Higgins. That identifies the issuing authority for the instrument but does not set out an internal appeal or review mechanism in the Directive itself.

Constraints on discretion

• The Directive’s language is mandatory, not advisory. The duty to determine applicability and to perform required actions where applicable is framed as an instruction rather than guidance. However, the Directive does not set out penalties or enforcement steps, and does not provide procedural protections such as variation or deferral within its text.

Operational practicalities

• Implementing the duties requires technical work often handled by maintenance organisations, plus aviation records review. Operators will need to reconcile DGAC AD requirements with their existing maintenance programmes and the aircraft’s configuration records to discharge the duty to determine applicability.

In short, the Directive imposes affirmative, time-limited duties on operators and maintenance providers to consult a defined set of State of Design ADs and implement the required actions where applicable, with an expectation that records will justify any finding of non-applicability or prior accomplishment.

The Directive’s text does not set out specific penalties or an enforcement procedure within the document itself. It is an administrative airworthiness directive that specifies mandatory obligations and deadlines, but does not include express sanctioning language, monetary fines, or a graduated enforcement ladder. The instrument identifies the issuing authority and effective date, and imposes compliance requirements; it does not within its pages define enforcement consequences.

What the Directive does show

• Mandatory obligations and deadlines. The Directive imposes a short compliance window for certificated aircraft (30 days after the effective date) and conditions certificate of airworthiness issuance for non-certificated aircraft on completion of the required actions (Compliance). These are operational levers that can be used by CASA and certification authorities at the point of certificate issuance.

• Delegated issuance. The document is signed by a CASA delegate. The presence of the delegate signature indicates the directive is an enforceable administrative instrument within CASA’s regulatory toolkit, even though the Directive text does not itself specify penalties.

What is not in the Directive

• No penalties specified. The Directive does not itself prescribe penalty amounts, license suspensions, or administrative fines.

• No enforcement steps described. There is no staged compliance remedy such as notices to comply, remediation timelines beyond the 30-day window, or appeal pathways set out in the AD text.

Consequences in practice (analytical observation, text-supported limits)

• Compliance uncertainty. Because the Directive does not state enforcement measures, affected parties face compliance uncertainty. The mandatory nature of the obligations combined with the absence of explicit sanctioning language increases the practical importance of documenting determinations and completion records. The Directive’s compliance timing tied to certificates of airworthiness is a specific enforcement mechanism at the point of certification: for aircraft not yet certificated CASA or the certifying body can delay or refuse issue of the certificate until the required actions are completed (Compliance).

• Risk of regulatory action. The Directive is a formal CASA instrument. Failure to comply with CASA directives is likely to attract regulatory follow-up under CASA’s general regulatory powers even if the Directive itself does not specify sanctions. That is an inference from the administrative context rather than a provision of this Directive; the Directive itself does not spell out post-breach remedies or procedures.

• Commercial and operational consequences. Non-compliance may produce operational consequences such as grounding for maintenance, denial of certificate issuance, or increased scrutiny by regulators, and will create liability exposure in circumstances where an operator cannot show compliance with applicable airworthiness directives. The Directive’s Background emphasises the safety rationale for compliance with State of Design ADs, implicitly linking non-compliance to continuing airworthiness risk.

Recommended practical approach given the absence of penalties in the text

• Operators should treat the Directive as a binding, time-limited obligation and document both the applicability determinations and the actions taken to comply. Given the Directive ties compliance to certificate issuance for non-certificated aircraft and imposes a 30-day deadline for certificated aircraft, prompt action and robust record-keeping will mitigate regulatory and operational risk.

In summary, the Directive imposes clear obligations and deadlines but does not itself state penalties or the enforcement procedure. The practical enforcement mechanisms are the compliance deadlines, the certificate-issue gate, and likely follow-up under CASA’s broader regulatory regime, none of which are defined in the Directive’s text.

The Directive occupies an operational niche in the broader regulatory framework for continuing airworthiness. The instrument explicitly imports State of Design airworthiness directives (DGAC ADs) into the Australian regulatory context for A330 aeroplanes, but it does not repeal, override, or restate other statutory provisions. The Directive therefore interacts with other regulatory instruments and administrative processes in specific ways.

Interaction with State of Design ADs

• Incorporation by reference. Rather than restating technical requirements, the Directive requires operators to adopt and implement the DGAC ADs listed in Table 1 where applicable (Requirement 1 and 2). This is an incorporation-by-reference interaction: CASA uses its domestic regulatory instrument to require compliance with foreign State of Design ADs.

Interaction with airworthiness certification processes

• Certificate of airworthiness condition. The Compliance text draws a direct interface with the certificate-of-airworthiness process. For aeroplanes that do not yet have a certificate of airworthiness, the Directive requires completion of applicable DGAC AD actions “before issue of the certificate of airworthiness” (Compliance). That creates a direct operational interaction: the airworthiness certification authority must verify completion before issuing a certificate.

Interaction with continuing airworthiness obligations

• Maintenance programmes and airworthiness records. Operators’ continuing airworthiness duties will be informed by the Directive. The requirement to determine applicability and perform actions where applicable will feed into maintenance schedules, modification records, and continuing airworthiness management procedures. The Directive presumes that operators will adopt the DGAC AD requirements into their continuing airworthiness records and maintenance release processes.

Interaction with foreign regulatory materials

• Cross-jurisdictional reliance. The Directive relies on DGAC ADs and provides URLs to EASA and GSAC web portals (Note 1). That creates an inter-jurisdictional link whereby Australian compliance is achieved by reference to documents produced by a foreign State of Design authority. Operators must therefore reconcile the DGAC AD technical content with Australian regulatory expectations and local maintenance standards.

Interaction with prior compliance and records

• Recognition of prior accomplishment. The Requirement permits an operator to avoid duplicative work where a DGAC AD has been “previously accomplished” (Requirement 2). That interacts with record-keeping regimes, because operators must demonstrate prior accomplishment with maintenance records, modification certificates or other documentary proof.

Limits and gaps in interaction

• No express interaction with amendment or review pathways. The Directive does not state how it interacts with alternative means of compliance, with variances or exemptions, or with appeals and reviews. It does not specify whether compliance may be achieved by an equivalent alternative method, nor does it identify a CASA contact for technical queries. That leaves a procedural gap as to how operators should proceed if a DGAC AD is unclear or if the AD cannot be complied with within the prescribed timeframe.

• No mention of penalties or enforcement mechanisms in the instrument. As discussed earlier, the Directive does not set out specific enforcement steps, fines or sanctions. Its practical enforcement nodes are the certificate issuance gate for non-certificated aircraft and whatever regulatory measures CASA may take under its broader powers.

Operational implications

• Operators need to align the DGAC AD actions with domestic maintenance release procedures and the aircraft’s maintenance data. The Directive’s incorporation-by-reference model means the technical heart of compliance is in documents outside this Directive, so the interaction between foreign AD text and local paperwork is central to execution.

In short, the Directive acts as a translator of State of Design ADs into an Australian compliance requirement and interposes itself into the certification and continuing airworthiness processes. It does not, however, specify procedural remedies, alternative compliance mechanisms or enforcement particulars, leaving those interactions to the broader CASA regulatory regime and operational practice.

The document identifies itself as AD/A330/112, and shows an effective date: “This Amendment becomes effective on 30 April 2010.” The date on the signature block is 8 April 2010 and the document is marked 8/2010. The Directive’s title lines show AD/A330/112 repeated and “State of Design Airworthiness Directives 8/2010” in the header area. Those features indicate (1) this instrument is an amendment-level AD, and (2) its effective and issue dates are April 2010.

What the document shows about prior material

• The Table 1 entries list multiple DGAC AD numbers with issue dates ranging from 1998 through 2003. Those listed items are State of Design ADs with their own issue dates and revision statuses, for example 1998-268-073(B) R3 (27/12/2000), 1998-484-081(B) R2 (17/05/2000), and 2001-320(B) R1 (17/09/2003). The Directive therefore aggregates prior DGAC ADs into a single Australian directive.

• The Background explains the reason for this amendment: the DGAC ADs are once-only actions with compliance dates or periods that have passed; CASA determined these ADs may be applicable to aircraft that were recently registered in Australia; the Directive is therefore issued “to ensure all State of Design ADs are complied with.” That language is a policy justification for the amendment.

What is not present

• The Directive text does not include a chronological list of previous Australian ADs on the A330 or earlier versions of AD/A330/112. It does not show an amendment-by-amendment log within the body of the document. The only amendment history explicitly present is the effective date and the listing of DGAC ADs with their original issue dates.

• There is no express description of whether AD/A330/112 supersedes any prior CASA directive, or whether it is an initial directive for Australian-registered A330s. The document’s header repeats the AD number and the grouping suggests it is the operative CASA measure at that time, but no cross-reference to previous CASA instruments is supplied in the text.

Analytical consequences

• CASA’s approach appears to be one of retroactive capture of State of Design actions for aircraft that entered the Australian register after original DGAC compliance windows. The aggregation of many DGAC ADs into a single Australian Directive suggests an administrative effort to close compliance gaps for imported or newly-registered aircraft. The Directive’s effective date and the DGAC AD issue dates create a temporal profile: the technical requirements were issued years earlier by the DGAC, and CASA’s April 2010 amendment imposes them on the domestic fleet with a short compliance window.

• Because the Directive does not set out a multi-stage amendment log, users must rely on the text and the listed DGAC AD numbers to trace technical evolution. Operators will need to consult the DGAC ADs themselves to understand the exact technical obligations and their revision histories.

Recommendation for practitioners handling amendment history

• When advising clients or conducting due diligence, trace each DGAC AD listed in Table 1 to its current technical revision at the DGAC or EASA/GSAC URLs provided. Record the revision history and confirmation that the AD action has been accomplished or not. Where an operator has documentation of prior accomplishment, retain the original maintenance release, modification certificate or equivalent evidence, and cross-reference it to the DGAC AD number and the CASA Directive.

In summary, the Directive is an April 2010 CASA instrument that consolidates and re-imposes a set of older DGAC AD requirements on Australian-registered A330 aircraft. The document itself provides limited amendment history beyond its effective date and the issue dates of the referenced DGAC ADs, so practitioners will need to consult the referenced DGAC materials to reconstruct technical amendment trajectories.

The Directive contains no record of litigation. The text does not refer to any judicial or administrative decisions, and there are no case references, dispute outcomes or examples of enforcement actions included. The document is a stand-alone administrative airworthiness directive issued by CASA on 8 April 2010 and effective 30 April 2010.

What the document does show on dispute potential

• The Directive is mandatory in wording and places new compliance obligations on operators for once-only actions the DGAC had previously required. That creates a potential locus for dispute about applicability determinations, the sufficiency of evidence of prior accomplishment, or the technical feasibility of complying within the 30 day window for certificated aircraft. However, the Directive itself does not set out dispute resolution pathways, appeals, or review mechanisms.

Implications for potential litigation

• Lack of procedural detail in the Directive may give rise to administrative law challenges in a hypothetical case where an operator disputes CASA’s action on procedural fairness grounds, or seeks judicial review of CASA’s application of the Directive to a particular aircraft. Because the Directive does not specify how an operator should seek an alternative method of compliance or a deferral, disputes could revolve around procedural fairness, legitimate expectations, or failure to provide sufficient guidance. None of those issues are mentioned in the Directive itself.

• The Directive’s compliance tie to certificate issuance is a practical enforcement mechanism. If CASA or the certifying authority refuses to issue a certificate because a required DGAC AD has not been implemented, that administrative decision could, in other circumstances, be the subject of review. The Directive itself contains no litigative history and does not identify any administrative tribunals or appeal routes in its text.

Recommendation for practitioners

• Because no litigation history is recorded, practitioners dealing with disputes arising from this Directive should document their applicability determinations, the technical basis for non-applicability where relevant, and any communications with CASA or certification bodies. Those records will be important if an operator seeks administrative review or legal relief in relation to a denial of certificate issuance or enforcement action.

In short, the Directive contains no litigation history or case law references. The absence of procedural detail in the directive could create grounds for administrative disputes, but the Directive itself includes no litigation information or pathways.

This Directive is short, but several practical and legal pitfalls can trap operators who do not read and act promptly. The following items are concrete issues derived from the Directive’s text and structure.

1. Short compliance window for certificated aircraft. The Compliance clause requires that, for aircraft that already hold a certificate of airworthiness, the required actions be completed within 30 days after the Directive’s effective date. The directive’s effective date is 30 April 2010 and the issue date is 8 April 2010. Operators who do not act quickly may find themselves outside the deadline and exposed to regulatory scrutiny. The 30-day window is tight for ADs that require modifications, part procurement, or airframe disassembly.

2. Pre-certificate gate for non-certificated aircraft. For aircraft that have not yet been issued a certificate of airworthiness, the required actions must be done before the certificate is issued. That creates a gatekeeping obligation that can delay entry into service or a transfer of registry if the operator has not already confirmed compliance.

3. Determination of applicability is an operator duty. The Requirement places the onus on the operator to determine whether each DGAC AD applies. That requires careful review of the DGAC AD texts against the specific aircraft’s serial number, configuration, modification status and installed parts. Failure to document a careful determination risks later regulatory challenge.

4. “Previously accomplished” is a binary escape valve but requires documentary proof. The Directive says if a DGAC AD “has been previously accomplished,” the operator need not repeat the action. Practically, operators must hold maintenance records or modification certificates that expressly map to the DGAC AD actions. Vague records or incomplete paperwork may not satisfy the “previously accomplished” requirement.

5. Multiple ADs and technical scope. Table 1 lists many DGAC ADs covering a broad range of systems: landing gear doors, slide locking mechanisms, door stay mechanisms, elevator servo eye-ends, P&W engine supports and barrel nuts, hydraulic systems, RAM turbine, escape slides, fuselage reinforcement and more. Some of these actions could be intrusive, require parts that are back-ordered, or require OEM involvement. Under the 30-day window, operators may struggle to obtain parts and schedule qualified maintenance organisations.

6. Differences in aircraft configuration and modification status. The Background explicitly recognises that some ADs will not be applicable because of aircraft manufacture date or configuration. However, operators must be able to show the factual basis for such a conclusion. Where an aircraft’s modification history is incomplete, uncertainty may force operators to perform work that may actually be unnecessary.

7. Reliance on external DGAC documentation. The Directive does not include the technical instructions; it points to DGAC/EASA/GSAC websites (Note 1). The operator’s ability to comply therefore depends on accessing the correct DGAC AD editions. Links or web portals may be updated, reorganised or offline; the operator must ensure it is consulting the correct AD revision referenced in Table 1 (including revision letters such as R1 or R2 where shown).

8. No AMOC or variance process in the text. The Directive contains no express mechanism for alternative methods of compliance or deferral. If a listed DGAC AD is technically infeasible to implement in 30 days or the owner believes an equivalent level of safety has been achieved by another modification, the Directive does not specify how to obtain CASA approval for an alternative. Absence of an AMOC route in the text creates a procedural gap.

9. Evidence standard for conformity. The Directive does not define the standard of evidence for conformity or what documentation suffices to demonstrate completion or non-applicability. Operators should not assume informal notes suffice; formal maintenance releases, modification certificates, or engineering approvals will be required in practice.

10. Potential downstream operational disruption. Actions required by DGAC ADs could require aircraft downtime, re-certification of modified systems, or re-programming of maintenance schedules. Under the 30 day window, compressed scheduling could be costly and disruptive.

11. No penalties or enforcement steps stated. Because the Directive does not specify enforcement outcomes, operators may underappreciate the seriousness of the obligation. The lack of stated penalties is not an invitation to delay; it is an ambiguity that increases the value of prompt, documented compliance.

12. Aggregation risk. The Directive aggregates many DGAC ADs into a single compliance obligation. An operator who fails to map each AD to the aircraft’s configuration may miss obligations across systems. A systematic cross-check is needed.

13. Responsibility fragmentation. Where ownership, operation and maintenance responsibilities are split between different entities, there can be gaps in compliance action. The Directive places the duty on “operators” and responsible persons, but does not prescribe how obligations are allocated among owners, operators and maintenance providers. Contractual clarity is therefore essential.

Practical short checklist of gotchas

• Do not assume a short record demonstrates prior accomplishment; retain formal releases/engineering orders.
• Verify you are reading the exact DGAC AD revision listed in Table 1.
• Start procurement of parts immediately if an AD requires replacement items.
• If the aircraft is not certificated, do not attempt to issue a certificate until the applicable AD actions are completed and evidenced.
• Document the technical basis for any non-applicability determination, including part numbers, serial numbers and modification records.

These are concrete, text-grounded operational risks that arise from the Directive’s structure, timing, and reliance on external State of Design ADs.

The Directive sets a clear two-step operative requirement and a compliance timetable. Below is a practical, evidence-focused compliance roadmap consistent with the Directive’s text and the operational realities the Directive requires.

Step 1 , Immediate administrative triage (Day 0 to Day 3)

• Identify all Australian-registered A330 series aeroplanes in your responsibility. The Directive applies to “All A330 series aeroplanes” (Applicability).

• Note the effective date: 30 April 2010. For certificated aeroplanes the window is 30 days after that date. For non-certificated aeroplanes compliance must be before certificate issue (Compliance).

• Assign responsibility. Nominate the person or role responsible for the applicability determination and for liaising with maintenance organisations. Record that nomination in the organisation’s continuing airworthiness management files.

Step 2 , Collect aircraft configuration and maintenance history (Day 0 to Day 7)

• Pull the aircraft’s maintenance records, modification history, parts and serial number lists, SB (Service Bulletin) incorporation records, life-limited parts logs, structural repair records, and historical AD compliance documentation.

• Create an aircraft-specific configuration matrix listing items relevant to each DGAC AD in Table 1, such as door types, landing gear bogie variants, engine installations (P&W variants), hydraulic system reservoirs, and escape slide/raft configurations.

Step 3 , Access and review the DGAC ADs listed in Table 1 (Day 1 to Day 10)

• Use the URLs provided in Note 1 to access the DGAC AD texts: the Directive lists http://ad.easa.europa.eu/ and http://www.gsac.fr/php/P_ConsignesNav.php. Confirm you are reviewing the exact DGAC AD number and revision listed in Table 1 (for example 1998-268-073(B) R3). Record the DGAC AD revision date and extract the required actions verbatim into your compliance matrix.

• For each DGAC AD, capture the action type (inspection, modification, part replacement, reinforcement), required materials/parts, special tooling, and whether the AD is “once-only” as described in the Directive’s Background.

Step 4 , Determine applicability (Requirement 1)

• For each DGAC AD listed in Table 1, compare the DGAC AD applicability criteria to the aircraft’s configuration matrix. Document the basis for each applicability decision, including reference to serial numbers, part numbers, installed equipment, and modification records.

• For ADs determined not applicable, prepare a short statement of non-applicability, cross-referencing documentary evidence. Keep these statements in the continuing airworthiness file.

Step 5 , Confirm prior accomplishment (Requirement 2, escape valve)

• Search historical records for evidence that the DGAC AD action has already been carried out. Evidence should be robust: maintenance release, certificate of alteration, engineering order, signed logbook entry, or equivalent. Where prior accomplishment is shown, file the record and mark the AD as satisfied.

• If prior accomplishment cannot be evidenced to the standard required by maintenance release practice, treat the AD as not previously accomplished and proceed to Step 6.

Step 6 , Implement required actions where applicable and not previously accomplished

• For ADs that apply and have not been previously accomplished, schedule the required technical work with an approved maintenance organisation or competent engineer. Ensure the maintenance organisation understands the DGAC AD action and is prepared to issue the appropriate release to service or modification certificate.

• Procure required parts and tools. Some DGAC ADs may require OEM parts or specific approved modification kits. Log purchase orders, expected lead times and alternative sourcing where appropriate.

• For work that may affect structural integrity or certification, ensure that the work is authorised under an appropriate engineering authority or approved design organisation as required by Australian continuing airworthiness rules.

Step 7 , Evidence of completion and certification

• Upon completion, obtain formal evidence: maintenance release, certificate of modification, engineering release, logbook entry and any test reports required by the DGAC AD.

• For non-certificated aeroplanes, do not issue a certificate of airworthiness until the applicable DGAC AD actions are completed and documented, as the Directive requires completion before certificate issuance (Compliance).

• For certificated aeroplanes, ensure completion and documentation within the 30-day window after the Directive’s effective date. Retain all completion evidence in the continuing airworthiness records.

Step 8 , Update continuing airworthiness management systems

• Record the AD compliance status for each DGAC AD in the operator’s airworthiness directive register and maintenance programme. Update future maintenance planning and any applicable life limits or inspection intervals introduced by the DGAC AD action.

Step 9 , Audit trail and risk management

• Create an audit trail demonstrating: (a) the DGAC AD text consulted, (b) the applicability determination with supporting evidence, (c) the evidence of prior accomplishment if applicable, and (d) the post-action maintenance documentation. This audit trail will be essential in any later regulatory inquiry.

• Where the operator believes an alternative method of compliance should be acceptable, document the technical rationale, the equivalent safety argument, and any supporting engineering data. The Directive does not specify an AMOC pathway; therefore, any such submission should be handled through existing CASA channels outside the Directive text with a documented record of the approach.

Step 10 , Practical timing and procurement considerations

• If the DGAC AD requires parts that have long lead times, prioritize procurement immediately. Given the 30-day window for certificated aircraft, operators with long procurement lead times should document efforts and communications showing proactive steps to comply.

• Where multiple DGAC ADs affect different systems, coordinate scheduling to reduce aircraft downtime,for example combine work that requires access to the same structure or system.

Recommended documentation checklist

• Copy of DGAC AD(s) referenced by Table 1, including revision identifiers.
• Configuration matrix linking the aircraft to each DGAC AD applicability criterion.
• Evidence of prior accomplishment: modification certificates, maintenance releases, logbook entries.
• Work orders, maintenance reports and certificates of release to service for newly-performed AD actions.
• Non-applicability statements with supporting documentary evidence where an AD does not apply.
• Communication logs with maintenance organisations and parts suppliers.
• Updated AD register entry with date of completion or non-applicability rationale.

Final operational note

• Because the Directive is an incorporation by reference of State of Design requirements, ensure that the technical content of the DGAC ADs is applied exactly as written unless an approved alternative is obtained from CASA. The Directive provides the obligation and the timelines; the technical means are defined in the DGAC AD texts listed in Table 1.

Follow these steps to convert the Directive’s procedural two lines into an auditable compliance programme that meets the timing conditions set out in the Directive’s Compliance clause.