AD/A330/17 Amdt 3 - Type A Passenger/Crew Door Slide Rafts and Type 1 Emergency Door Slides

The AD uses a small set of administrative and technical concepts to create its effect. These concepts are stated in the text and are the only source-authorised points for downstream compliance and analysis.

• Applicability. The AD identifies affected aircraft by model (A330-200 and A330-300), serial number (all serial numbers), and equipment configuration (aircraft "equipped with Goodrich slides and slide rafts with part numbers listed in the Effectivity section of DGAC AD F-2004-094 R1"). The AD does not itself list part numbers; it delegates effectivity determination to the DGAC AD.

• External incorporation. The AD does not set out the specific work; it requires "Action in accordance with the requirements of DGAC AD F-2004-094 R1." This is a legal mechanism of incorporation by reference: the Australian AD makes compliance with a foreign regulator's AD mandatory for the affected Australian fleet.

• Terminating modification. The Background records that "Amendment 2 mandated a terminating modification of the Vespel piston inner diameter as per Goodrich VSB 25-347 to ensure correct operation of the regulator valve." The phrase terminating modification, as used in the AD, means that after the specified modification is carried out as per the named Goodrich service bulletin, the aircraft may be relieved from recurring requirements that the DGAC AD otherwise mandated. The AD text does not itself define the scope or method of the modification; it prescribes the Goodrich VSB as the normative technical document.

• Inter-references to manufacturer and regulator documents. Amendment 3 "is issued in response to a revision of the related DGAC AD, which adds information on aircraft affected; and references the applicable AIRBUS service bulletin in the Mandatory Actions and Compliance Times section of the AD." Thus the AD relies on both Goodrich and Airbus service documentation as the technical sources for mandatory actions and compliance times.

• Safety rationale. The Background states the operational safety concern: regulator valve malfunction prevented gas release, producing non-deployment of Type A door slide rafts during maintenance tests, in automatic and manual modes. The AD frames the mandated modification as correcting regulator valve behaviour.

• Administrative effectivity. The AD includes an explicit effective date: "This Amendment becomes effective on 4 June 2009." The AD is signed by a CASA delegate, which indicates internal regulatory authorisation.

These are the main legal-technical building blocks. The AD does not itself provide compliance intervals, specific torque values, part numbers, step-by-step procedures or enforcement mechanisms. Those items are instead defined in the named DGAC AD, Goodrich VSB 25-347, and the Airbus service bulletin referenced in the DGAC AD.

The AD expressly affects a clearly defined group and indirectly implicates certain third parties through its incorporation of external documents.

• Operators and owners of A330-200 and A330-300 aircraft. The Applicability clause limits the binding effect to "All Model A330-200 and A330-300 series aircraft, all serial numbers, equipped with Goodrich slides and slide rafts with part numbers listed in the Effectivity section of DGAC AD F-2004-094 R1." That language makes operators and owners who have those part-numbered Goodrich slides/slide rafts on their A330s the primary obligated parties. The AD does not, in its text, designate other categories such as lessors or maintenance organisations as separately obligated, but by operation of typical aviation regulation the operator is the party that must see that the aircraft complies.

• Maintenance organisations and licensed aircraft engineers. The Background describes the malfunctions as being revealed in maintenance tests. The required actions are technical (inspection, tests, terminating modification per Goodrich VSB 25-347 and Airbus service bulletin as referenced). Implementing those actions will fall to maintenance organisations and licensed engineers who carry out the parts replacement, dimensional modification of a Vespel piston or the tests specified in the referenced documents.

• Parts manufacturers and suppliers. Goodrich is named as the supplier of the slides and slide rafts, and Goodrich VSB 25-347 is the normative modification document for the Vespel piston inner diameter. Airbus is also implicated because Amendment 3 adds a reference to an Airbus service bulletin in the Mandatory Actions and Compliance Times section of the related DGAC AD. Therefore Goodrich and Airbus are the technical sources whose parts and service information are incorporated into the mandatory requirements.

• Civil Aviation Safety Authority. The AD is issued by a CASA delegate (signature appears as "David Villiers, Delegate of the Civil Aviation Safety Authority"). CASA is therefore the enforcing regulator in Australia insofar as it has jurisdiction to issue ADs and supervise airworthiness compliance.

• Regulators abroad and document holders. The AD relies on DGAC AD F-2004-094 R1 (DGAC is the French civil aviation authority). The AD therefore engages cross-jurisdictional regulatory documents. Operators must consult DGAC AD F-2004-094 R1 and the manufacturer service information it references to determine applicability and required work.

• Airlines' operational planners and safety/compliance teams. The AD creates a maintenance obligation that will affect aircraft dispatchability and maintenance scheduling. Although the AD does not itself set labour times or cost, it will have direct operational implications for scheduling and potentially aircraft availability during the work.

The AD text does not identify compensation arrangements, financial assistance, or specific responsibilities of lessors. It states who the affected aircraft and technical documents are, and delegates technical steps to the named foreign AD and service bulletins. Determining the ultimate contractual allocation of compliance costs between owner, operator and lessor therefore requires reference to lease agreements and commercial contracts outside the AD text.

The AD establishes a single, primary statutory duty and leaves implementation detail to the referenced documents.

• Mandatory action duty. The core duty is: "Action in accordance with the requirements of DGAC AD F-2004-094 R1" (Requirement). That duty is mandatory from the effective date set by the AD: "This Amendment becomes effective on 4 June 2009." The AD therefore imposes an obligation on operators of affected aircraft to carry out whatever inspections, tests, modifications and compliance steps the DGAC AD prescribes.

• Terminating modification duty. As recorded in the Background, Amendment 2 "mandated a terminating modification of the Vespel piston inner diameter as per Goodrich VSB 25-347 to ensure correct operation of the regulator valve." Where the DGAC AD specifies recurrence or repetitive inspections, the named terminating modification, once carried out in accordance with Goodrich VSB 25-347, will serve to end those recurring obligations where the DGAC AD designates that modification as terminating. The AD text itself does not recite the detailed criteria for the terminating status; the Goodrich VSB and DGAC AD must be consulted.

• Duty to determine applicability. Because the AD's Applicability relies on part numbers listed in the Effectivity section of DGAC AD F-2004-094 R1, operators have the duty to identify whether their particular aircraft, and the slide/raft part numbers installed, fall within the DGAC AD effectivity. The Australian AD does not itself list those part numbers.

• Duty to consult referenced documents. The AD's compliance clause "As specified in the Requirement document" places a practical duty on operators and maintenance organisations to obtain and read DGAC AD F-2004-094 R1 and the Goodrich VSB 25-347 and Airbus service bulletin referenced by DGAC AD in order to comply. The AD makes those external documents the source of mandatory steps and compliance times.

• Rights implicit in the instrument. The AD does not set out express rights such as appeal or review mechanisms. It does record the issuing authority (the CASA delegate). Any rights to seek variation, approval of alternative methods of compliance (AMOCs), or to challenge the AD are not included in the text provided. The AD does not itself include provisions for equivalent means of compliance within its text; therefore rights to seek alternative compliance must be pursued under the broader regulatory framework or internal CASA processes, which the AD does not state.

• Record-keeping and proof of compliance. The AD does not specify record-keeping procedures. In practice, demonstrating compliance with the DGAC AD and the Goodrich and Airbus service documents will require maintenance records, certification by authorised personnel and retention of receipts/part numbers, but the AD text itself only sets the obligation to "Action in accordance with the requirements of DGAC AD F-2004-094 R1."

In short, the AD delegates substantive work to the DGAC AD and manufacturer service information. The key duty is to implement those requirements; the operator and their maintenance providers must identify affected aircraft via the DGAC AD effectivity and perform the terminating modification where applicable pursuant to Goodrich VSB 25-347 and the Airbus service bulletin referenced.

The AD text supplied contains no express penalties, monetary fines, or enforcement mechanisms. It is an instrument that prescribes mandatory airworthiness work by reference, and it is signed by a CASA delegate ("David Villiers, Delegate of the Civil Aviation Safety Authority, 17 April 2009"), which establishes it as an official regulatory action. Beyond that, the AD itself is silent on sanctioning language.

• No penalties in text. The supplied AD does not include any specific penalty provisions or enforcement procedures. There is no section in the text stating fines, suspension or other administrative sanction. The AD instead focuses on applicability, requirement, compliance statement and background.

• Enforcement implication. The AD’s status as an airworthiness directive issued by CASA implies that non-compliance would be an airworthiness matter subject to the broader statutory enforcement powers of the regulator, but those statutory powers and enforcement procedures are not contained in the AD text provided. The AD gives the operative compliance obligation (by cross-reference to the DGAC AD and manufacturer service bulletins) and records the effective date. Any enforcement action for breach of the AD would therefore rely on the existence of enabling legislation and enforcement policies outside the AD itself.

• Practical enforcement mechanisms not set out. The AD does not specify how CASA will verify compliance, whether it will require operators to submit proof, or whether audits/inspections will be carried out. It does not state whether AMOCs (alternative methods of compliance) may be approved, or the procedural route for obtaining deviations or extensions. Those processes, if available, will be found in CASA’s broader procedures rather than in the AD text as provided.

• Record of amendments. The Background describes prior amendments and the technical reasons for them; that history is material to enforcement because regulators commonly demand evidence that the required terminating modification (Goodrich VSB 25-347) has been accomplished in the manner specified by the AD and referenced service information.

Users of the AD must therefore recognise that the document itself mandates compliance by cross-reference, but that any enforcement steps, remedies or sanctions will be governed by statutory instruments and CASA enforcement practice not reproduced in the supplied AD text.

The AD is explicitly cross-referential and therefore interacts with a set of external regulatory and technical documents rather than creating a self-contained regulatory regime.

• Incorporation of foreign regulator AD. The Requirement clause makes DGAC AD F-2004-094 R1 the substantive source of mandatory action. The DGAC AD is the French authority document. The Australian AD therefore enforces a foreign AD on the specified Australian-applied aircraft. The AD further states that Amendment 3 "is issued in response to a revision of the related DGAC AD, which adds information on aircraft affected; and references the applicable AIRBUS service bulletin in the Mandatory Actions and Compliance Times section of the AD." This demonstrates that Australian enforcement relies on the content and revisions of the foreign AD.

• Incorporation of manufacturer service bulletins. Amendment 2 mandated a terminating modification per Goodrich VSB 25-347. Amendment 3 references an Airbus service bulletin as the document setting mandatory actions and compliance times for the related DGAC AD. Therefore the AD links statutory compliance to manufacturer technical documents. The interplay is that the regulator sets the legal obligation, and the OEM/parts-supplier documents set the technical specification and procedures to meet that obligation.

• Regulatory hierarchy and delegation. The AD is issued by a CASA delegate. The AD does not reproduce the enabling statute authorising CASA to make ADs; those statutory provisions are not contained in the text supplied. The interaction with other laws therefore includes whatever enabling legislation allows CASA to require compliance with ADs and to enforce airworthiness requirements, but those enabling provisions are outside the AD text.

• International harmonisation. By mandating compliance with DGAC AD F-2004-094 R1, the Australian AD aligns Australian regulatory obligations with a DGAC action. This may affect operators who also must meet other jurisdictions’ ADs; the AD does not attempt to reconcile differences between DGAC AD F-2004-094 R1 and other jurisdictions’ directives. The AD expressly notes that the DGAC AD's Effectivity section contains the part numbers that determine applicability.

• Contractual and commercial interactions. The AD does not address lease arrangements, warranties, indemnities or allocation of cost. However, it intersects with contracts because compliance will impose costs and downtime that will typically be allocated between lessors, lessees and maintenance providers under commercial agreements. The AD itself does not modify or specify those contractual allocations.

• No express conflict resolution language. The AD does not state that compliance with the DGAC AD will supersede any conflicting instructions or that alternative methods are permitted. Any legal conflict between this AD and other domestic regulatory requirements would require interpretation under broader aviation law and administrative law, which are not included in this text.

In sum, the AD’s legal force comes from CASA’s issuance, but its substantive technical requirements and the determination of which aircraft are affected are derived from DGAC AD F-2004-094 R1 and the named OEM/parts-supplier service documents. Operators must therefore manage compliance by navigating the cross-jurisdictional and manufacturer-document relationships reflected in the AD.

The AD itself records three amendments and provides short explanations in the Background. The supplied text includes the history lines and the substance attributed to each amendment.

• Original AD and initial problem statement. The Background recounts that the DGAC received reports of non-deployment of Type A door slide rafts during maintenance tests, and that in all cases the regulator valve had malfunctioned and prevented gas release. The original AD responded to that safety issue by mandating certain corrective measures via the DGAC AD.

• Amendment 1. The Background records: "Amendment 1 corrected the compliance to align it with the DGAC Directive. This was an error in the original issue." That statement indicates that the original wording of the Australian AD contained a compliance clause inconsistent with the DGAC AD and that Amendment 1 corrected that inconsistency. The AD does not reproduce the prior incorrect text nor the precise correction language; it only states that alignment with the DGAC Directive was the purpose of Amendment 1.

• Amendment 2. The Background states: "Amendment 2 mandated a terminating modification of the Vespel piston inner diameter as per Goodrich VSB 25-347 to ensure correct operation of the regulator valve." That is a substantive technical amendment. It introduced a specific remedy,the Vespel piston inner diameter modification specified by Goodrich VSB 25-347,and characterised that remedy as terminating, meaning that completing that modification would end recurring obligations where that status is recognised in the DGAC AD.

• Amendment 3 (this instrument). The AD we have is Amendment 3. The Background describes Amendment 3 as being "issued in response to a revision of the related DGAC AD, which adds information on aircraft affected; and references the applicable AIRBUS service bulletin in the Mandatory Actions and Compliance Times section of the AD." Amendment 3 therefore updates the Australian AD to reflect changes in the DGAC AD, including the DGAC AD’s expanded effectivity and its reference to an Airbus service bulletin for mandatory actions and compliance times.

• Effective date and signature. The AD records its effective date as 4 June 2009 and is signed by the CASA delegate on 17 April 2009. The precise chronology indicates that the AD was issued in April 2009 and scheduled to come into force on 4 June 2009.

The amendment history in the supplied text is descriptive rather than legislative in the sense of reproducing amended operative paragraphs. It documents that the Australian AD has been adjusted to mirror the DGAC AD and to incorporate manufacturer-recommended terminating modifications. Operators must therefore consult the current DGAC AD and the Goodrich and Airbus service documents to see the current technical and compliance requirements in full.

The supplied AD text contains no record of litigation or judicial review relating to AD/A330/17 or its amendments. The document itself is an administrative regulatory instrument and the Background section describes the safety reports and amendment rationales, but there are no references to court decisions, notices of appeal, or disputes.

• No cases named. The AD does not cite any judicial or administrative case law, and it does not report any challenges to the AD or its antecedent DGAC AD or service bulletins.

• No administrative appeals or variation clauses shown. The AD does not set out any appeal mechanism within the text provided. It does not record that any party applied for or obtained relief from the AD. If litigation or administrative review occurred after this AD, that material is not contained in the supplied instrument.

• Practical consequence. For a practitioner seeking to assess legal risk, the absence of litigation history in the AD text means that one must look to external records: CASA enforcement records, court or tribunal databases, and industry notices. The AD itself provides no indication whether CASA has prosecuted non-compliance, accepted alternative compliance methods, or otherwise engaged in dispute resolution concerning these specific measures.

• Suggested next steps for legal research. Because the AD incorporates DGAC AD F-2004-094 R1, which is foreign to Australia, any disputes that have arisen in other jurisdictions (for example between operators and manufacturers or between operators and foreign regulators) would not be recorded in the Australian AD. A full litigation history relevant to the technical measures would therefore require searching administrative and judicial records outside the text provided. That step lies outside the AD as supplied and is not recorded within it.

In sum, the supplied instrument contains no litigation history. It is silent on appeals, challenges or enforcement actions, and any such material is not part of this text.

Because the AD relies heavily on external documents and limited internal text, there are several practical "watchpoints" that operators, maintenance organisations and legal advisers should note; each point is grounded in what the AD explicitly states.

• Applicability is not self-contained. The AD’s Applicability refers to part numbers that are "listed in the Effectivity section of DGAC AD F-2004-094 R1." The Australian AD does not list those part numbers. Practitioners must therefore obtain and check DGAC AD F-2004-094 R1 to determine whether a given aircraft is affected. Failing to consult the referenced DGAC AD could lead to misclassification of affected aeroplanes.

• Substantive requirements are external. The AD's operative command is "Action in accordance with the requirements of DGAC AD F-2004-094 R1." The AD itself does not reproduce inspection procedures, compliance intervals or the detailed scope of the modification. Operators must obtain the DGAC AD and the Goodrich and Airbus service information it references to know the precise steps required. The AD’s brevity creates a compliance-by-reference trap: the legal obligation exists in Australia but the technical instructions lie elsewhere.

• Terminating modification specifics are in Goodrich VSB 25-347. Amendment 2 "mandated a terminating modification of the Vespel piston inner diameter as per Goodrich VSB 25-347." To benefit from the terminating status and to ensure that the modification is performed correctly, organisations must obtain Goodrich VSB 25-347 and follow it precisely. The AD text does not provide interchangeability allowances or alternative methods.

• Amendment 3 references an Airbus service bulletin for compliance times. The Background states that Amendment 3 responds to a DGAC revision that "references the applicable AIRBUS service bulletin in the Mandatory Actions and Compliance Times section of the AD." This means that compliance times may now be specified by an Airbus service bulletin, not by the Australian AD text. Practitioners must therefore confirm which Airbus SB is referenced and the compliance timelines it contains.

• No enforcement language in the AD. The AD contains no penalties or enforcement procedures. Do not assume the AD is merely advisory. It is an enforceable regulatory instrument issued by CASA; however the AD text does not state the statutory enforcement route, appeal avenues, or AMOC process. Practitioners should look to CASA’s broader regulatory instruments to understand enforcement, approvals for alternative methods, and administrative remedies.

• Timing and effective date. The AD "becomes effective on 4 June 2009" but was signed on 17 April 2009. Operators should check whether any earlier or later revisions to the DGAC AD or the Goodrich/Airbus service bulletins have been issued since, because the Amendment 3 text indicates the Australian AD responds to DGAC revisions. The AD as supplied applies from 4 June 2009; later updates are not in this document.

• Maintenance-test origin of the reports. The Background notes that the non-deployments were discovered during maintenance tests. That suggests that test procedures, test intervals and maintenance quality control are relevant to reproduction of the defect and to mitigation. However the AD does not spell out testing protocols; these will be in the DGAC AD and manufacturer service documents.

• Parts and logistics. The AD requires a physical modification to the Vespel piston inner diameter as per the Goodrich VSB. The AD does not discuss parts supply, approvals for modified parts, or whether new parts will be supplied under warranty. These commercial and logistical matters are outside the AD text but are necessary to complete the mandated work.

• Cross-jurisdictional documentation. DGAC AD F-2004-094 R1 is a foreign regulator’s document. Practitioners should ensure they obtain an authoritative copy and verify it is the revision in force that the Australian AD references. The Australian AD was issued to align with a DGAC revision; misreading which version is referenced could produce compliance error.

These points are not speculative; each is directly supported by the AD text where the AD delegates effectivity, compliance and technical steps to the DGAC AD, Goodrich VSB 25-347 and an Airbus service bulletin. Practitioners must treat the AD as an enforcing shell that points to external technical documents for the actionable content.

The AD establishes a clear, document-driven compliance pathway. The AD itself does not provide procedural detail; the following steps reflect what the AD requires by reference and are grounded in the text.

1. Obtain the referenced documents. The Requirement clause mandates "Action in accordance with the requirements of DGAC AD F-2004-094 R1." Amendment 2 specifies Goodrich VSB 25-347 for the terminating modification and Amendment 3 indicates the DGAC AD references an Airbus service bulletin for mandatory actions and compliance times. Start by obtaining the exact revision of DGAC AD F-2004-094 R1 that the Australian AD references, the Goodrich VSB 25-347 document, and the Airbus service bulletin referenced in the DGAC AD.

2. Determine effectivity for each airframe. The Australian AD’s Applicability points to part numbers "listed in the Effectivity section of DGAC AD F-2004-094 R1." Inspect maintenance records to identify the Goodrich slide and slide raft part numbers installed on each A330-200 and A330-300 in the operator’s fleet. Cross-check those part numbers against the Effectivity section of DGAC AD F-2004-094 R1 to establish whether each aircraft is within the AD’s scope.

3. Follow the DGAC AD’s mandatory actions and compliance times. The Australian AD requires actions "in accordance with the requirements of DGAC AD F-2004-094 R1" and states "Compliance: As specified in the Requirement document." Implement the inspections, tests, repetitive checks or modifications exactly as specified in the DGAC AD and the Airbus service bulletin it references for Mandatory Actions and Compliance Times. Note the effective date of this Amendment: 4 June 2009.

4. If applicable, perform the terminating modification per Goodrich VSB 25-347. Amendment 2 "mandated a terminating modification of the Vespel piston inner diameter as per Goodrich VSB 25-347." Where the DGAC AD designates the Goodrich VSB modification as terminating, perform that modification strictly in accordance with Goodrich VSB 25-347 so that recurring inspections or actions cease as intended under the DGAC AD. Ensure the modification is certified by authorised maintenance staff and that records specify the Goodrich VSB reference and the serial numbers/part numbers modified.

5. Record compliance. The AD itself does not prescribe recordkeeping formalities, but operators should document obtaining the referenced AD and service bulletins, the determination of applicability for each airframe, the date and nature of inspections/tests, the parts modified or replaced, and the authorisation of maintenance personnel who performed the work. Retain these records for regulatory inspection and audit.

6. Coordinate with maintenance planners and operations. The AD will affect aircraft availability. Schedule the required inspections and terminating modification work in maintenance windows; liaise with parts suppliers (Goodrich/Airbus) to secure any parts or tooling required by Goodrich VSB 25-347 or the Airbus service bulletin.

7. Seek clarification or approvals if needed. The AD text does not specify an AMOC process or appeals route. If an operator believes an alternative method of compliance is warranted, or if the referenced documents are unclear, contact CASA for guidance and request formal approval of any alternative method under the regulator’s wider procedures. The AD does not itself provide that mechanism, so any formal approval will be via CASA outside the AD text.

8. Verify revisions. Amendment 3 followed a DGAC revision that added aircraft information and cross-referenced an Airbus service bulletin. Before acting, confirm that the DGAC AD revision referenced by the Australian AD is the current operative version for Australian compliance or whether subsequent DGAC or CASA revisions have altered requirements or effectivity.

9. Communicate to stakeholders. Notify lessors, insurers, and relevant contractual counterparties of the AD’s applicability and the planned compliance actions and timing. The AD does not allocate costs; contract parties will need to manage those commercial arrangements separately.

10. Preserve evidence for regulatory inspection. Although the AD does not describe enforcement steps, being able to demonstrate compliance with the DGAC AD, Goodrich VSB 25-347 and the Airbus service bulletin is the practical means to show conformance with this Australian AD.

These steps derive directly from the AD text: the Applicability clause defines the affected hardware; the Requirement clause makes DGAC AD F-2004-094 R1 normative; Amendment 2 points to Goodrich VSB 25-347 as the terminating modification; and Amendment 3 indicates that the DGAC AD references an Airbus service bulletin for mandatory actions and times. The AD places on operators the obligation to consult and implement the referenced documents and to ensure, from 4 June 2009, that affected aircraft comply with those requirements.