AD/B717/18 Amdt 1 - Passenger Oxygen Release System

The Directive rests on a small set of interlocking concepts that determine who must act, what must be done, and what can end the recurring requirement.

• Applicability by reference. The AD does not list individual serial numbers in the text supplied, it points to Boeing ASB 717-35A0003 Revision 1, dated 7 June 2005, to identify the affected McDonnell Douglas Model 717-200 aeroplanes (Applicability). That means the precise scope of aircraft covered is determined by the ASB’s identification criteria.

• Mandatory replacement and functional test. The core obligation is to "Replace the relay in the passenger oxygen release system in the forward cabin with a new relay and test for proper operation" in accordance with the Accomplishment Instructions of the ASB (Requirement). The AD treats prior compliance performed under the ASB dated 19 November 2004 as acceptable, so work done before the AD’s effective date in accordance with that earlier ASB meets the Directive’s requirement.

• Recurrence with defined cycle limit. The Directive imposes repetitive actions, with a maximum interval of 3,100 flight cycles between replacements/tests until the aircraft is modified under the specified Boeing Service Bulletin (Compliance). The recurrence is therefore a continuing operational maintenance burden until the terminating modification is installed.

• Optional terminating action via modification. Operators may elect to perform the modification described in SB 717-35-0004 (original issue dated 10 January 2006 or Revision 1 dated 3 May 2006) which, where applicable by aircraft group, is an optional terminating action to the repetitive inspections (Requirement). The AD notes that Revision 1 of SB 717-35-0004 requires more work for Group 2 and Group 3 aeroplanes (Note 1).

• Interoperability with FAA approvals. The AD explicitly accepts later revisions of ASB 717-35A0003 that have FAA approval as an Alternate Method of Compliance (AMOC) to FAA AD 2005-16-08, stating those later revisions are "considered acceptable for compliance with the equivalent Requirements of this Directive" (Requirement). The AD also references FAA AD 2005-16-08 Amdt 39-14213 (Note 2), signalling cross-recognition of FAA regulatory instruments and their AMOCs.

• Group-differentiated timing. The AD separates the fleet into groups as identified in the ASB and prescribes different initial compliance windows: Group 1 must comply within six months of the original issue of the Directive, and thereafter at intervals not exceeding 3,100 flight cycles, until modified; Group 2 must comply before 3,100 total flight cycles or within six months after the original issue of the Directive, whichever is later, and thereafter at intervals not exceeding 3,100 flight cycles until modified (Compliance). The text supplied does not reproduce the ASB’s group definitions; the ASB is therefore necessary to determine which aeroplanes fall into Group 1 or Group 2 (Applicability; Compliance).

• Safety rationale. The Background states the FAA received reports of failed relays in the passenger oxygen release system, creating the risk that masks would fail to deploy and deliver oxygen during rapid decompression or cabin depressurisation (Background). The Directive continues repetitive replacement/testing requirements and introduces an optional terminating modification.

These concepts structure obligations, compliance timing, and the path to terminating recurring obligations. The AD’s design leverages manufacturer service documents and an FAA AD framework, making the ASB and SB essential for both scope and method of compliance. The Directive leaves the precise group categorisation and detailed procedural steps to the service documents it references.

The Directive identifies its affected population by reference to Boeing ASB 717-35A0003, Revision 1, dated 7 June 2005. Concretely, the AD applies to "McDonnell Douglas Model 717-200 aeroplanes, as identified in Boeing Alert Service Bulletin (ASB) 717-35A0003, Revision 1, dated 7 June 2005" (Applicability). The AD does not list serial numbers or register entries itself in the supplied text; therefore, operators must consult the ASB to determine whether an individual aeroplane falls within the Directive’s scope.

Primary affected parties

• Air operators and aircraft owners who operate McDonnell Douglas Model 717-200 aeroplanes that the ASB identifies as in scope. These parties bear the primary compliance obligation to replace the forward-cabin passenger oxygen release relay and to perform the specified tests at the prescribed intervals (Requirement; Compliance).

• Maintenance organisations and engineers who must carry out the replacement and functional testing, and who will need access to and to follow the Accomplishment Instructions set out in ASB 717-35A0003 Revision 1 (Requirement). The AD makes those instructions the method for accomplishing the mandated work.

• Fleet maintenance planners and safety/compliance officers who will schedule recurring work at intervals not to exceed 3,100 flight cycles, and who will decide whether to adopt the optional terminating modification in SB 717-35-0004 (Compliance; Requirement).

• Regulators and delegated CASA personnel who monitor and enforce compliance with the AD. The instrument is issued by the Civil Aviation Safety Authority and is signed by a CASA delegate (James Coyne), and it becomes effective on a specified date (Background).

Indirectly affected parties

• Passengers, insofar as the Directive addresses an operational safety risk in passenger oxygen deployment systems (Background). The Directive aims to reduce the risk of failed mask deployment in rapid decompression or depressurisation events.

• Lessors and financiers, who typically require compliance with airworthiness directives as a condition of lease covenants and regulatory compliance for asset value preservation, will be indirectly affected because the asset must be maintained in accordance with the AD.

• Suppliers of replacement relays and parts, and Boeing as the manufacturer, who will be involved in providing parts and service bulletins that the AD references.

Who pays and who decides

• Operators and owners pay for the labour, parts, testing, and aircraft time necessary to perform the replacement and recurring tests, or to undertake the optional modification in the SB if they choose the terminating action. The Directive itself imposes the obligation; the ASB and SB contain the work instructions that determine the specific tasks.

• Decisions about whether to adopt the optional terminating modification rest with operators and their maintenance/engineering branches, subject to the applicability criteria in SB 717-35-0004 and any operational or commercial constraints. The Directive sets the incentive: continued recurring replacements/tests until the modification is installed.

Geographical and regulatory reach

• The AD is a CASA instrument and therefore binding on Australian-registered aircraft to which it applies. The Directive explicitly cross-references and accepts FAA approvals for later ASB revisions and the FAA AD 2005-16-08; that creates a mechanism for reciprocal recognition of certain FAA-approved compliance methods, but the AD itself is the operative Australian requirement for affected aircraft on the Australian register.

Duties imposed

• Replace the relay and test for proper operation. The Directive requires operators to "Replace the relay in the passenger oxygen release system in the forward cabin with a new relay and test for proper operation in accordance with the Accomplishment Instructions of ASB 717-35A0003, Revision 1, dated 7 June 2005" (Requirement). This is the core substantive duty, with the ASB providing the technical method.

• Perform repetitive work at specified intervals. For Group 1 aeroplanes, the AD requires compliance "within six months after the effective date of the original issue of this Directive and thereafter at intervals not to exceed 3,100 flight cycles, until the aircraft is modified in accordance with SB 717-35-0004 or Revision 1, as applicable" (Compliance). For Group 2 aeroplanes, the initial compliance is "before the accumulation of 3,100 total flight cycles, or within six months after the effective date of the original issue of this Directive, whichever is later, and thereafter at intervals not to exceed 3,100 flight cycles, until the aircraft is modified in accordance with SB 717-35-0004 or Revision 1, as applicable" (Compliance). The Directive thereby imposes a continuing maintenance schedule until the terminating modification is performed.

• Follow ASB Accomplishment Instructions. The AD makes compliance conditional on following the Accomplishment Instructions of ASB 717-35A0003 Revision 1 (Requirement). Prior work in accordance with the earlier ASB dated 19 November 2004 is explicitly accepted as compliant (Requirement).

Rights and optional choices

• Optional terminating action. Operators have the right to choose a terminating action by modifying the aircraft in accordance with Boeing Service Bulletin SB 717-35-0004, original issue dated 10 January 2006 or Revision 1 dated 3 May 2006, as applicable by aircraft group identified in the SB (Requirement). This is an affirmative option that, if exercised, ends the requirement for repetitive replacement/testing.

• Use of FAA-approved AMOCs for later ASB revisions. The AD affords operators the right to comply with later revisions of ASB 717-35A0003, provided those revisions are approved by the FAA as an Alternate Method of Compliance to FAA AD 2005-16-08; such later revisions are "considered acceptable for compliance with the equivalent Requirements of this Directive" (Requirement). That creates a path for operators to adopt FAA-approved variations to the ASB’s instructions and still meet the Australian AD requirement.

Operational discretion limited by the AD

• No deviation from the AD without accepted alternative. The AD ties compliance to the ASB’s instructions and to FAA-approved AMOCs where applicable; it does not supply other permitted alternatives in the text provided. Any alternative method of compliance would need to be accepted consistent with the regulatory processes that underpin ADs, but the AD itself references only the ASB, the SB, and FAA AMOCs (Requirement).

Timing obligations

• Initial compliance windows differ by group. The AD sets differing timeframes for initial compliance for Group 1 and Group 2 aircraft, creating a scheduling duty for operators to ensure the work is completed within the specified initial window before continuing with the established recurrence intervals (Compliance).

Documentation and proof of compliance

• The AD accepts earlier replacements and tests "accomplished before the effective date of this Directive in accordance with ASB 717-35A0003, dated 19 November 2004" as compliant (Requirement). Operators who can demonstrate they performed the earlier ASB work should be able to document compliance. The AD’s references to the ASB and SB also make those documents central to the evidence of proper method and scope.

The AD therefore creates mandatory duties for replacement and testing on a recurring basis, preserves an operator choice to adopt a terminating modification described in a Boeing Service Bulletin, and allows use of FAA-approved ASB revisions as acceptable methods of compliance. The duty to perform and to time the actions lies with operators and maintenance organisations; the AD prescribes the boundaries of acceptable methods and the recurrence timing.

The text of AD/B717/18 Amdt 1 supplied here does not state monetary penalties, criminal sanctions, or specific enforcement procedures or penalties that will be applied for non-compliance. The instrument is an Airworthiness Directive published by the Civil Aviation Safety Authority, signed by a CASA delegate (James Coyne), and contains effective dates and mandatory requirements (Background; Requirement; Compliance). From the text we can extract the following enforcement-relevant facts and practical implications based on how the Directive is structured.

• Issuing authority. The Directive is issued by the Civil Aviation Safety Authority and is signed by a CASA delegate (James Coyne). This identifies CASA as the issuing regulatory body, which places the Directive within the Australian aviation safety regulatory framework (Background).

• Effective date. The Amendment is stated to become effective on 27 August 2009, and the original Directive became effective on 29 September 2005 (Background). Effective dates create firm compliance deadlines operators must meet for the initial mandatory actions and recurring cycles.

• Compliance obligations. The AD sets out mandatory works tied to the ASB and SB. The AD explicitly accepts prior work completed in accordance with a specified ASB dated 19 November 2004. It also accepts FAA-approved AMOCs for later ASB revisions (Requirement). Those elements delineate acceptable modes of compliance against which CASA will assess whether operators have met their obligations.

• Enforcement mechanisms not specified in the text. The AD does not detail inspection, audit, certificate action, or civil/criminal penalty mechanisms in the supplied text. It also does not record specific administrative enforcement processes, infringement schedules, or fines. The absence of explicit penalty language in the instrument means that any enforcement or sanctioning would proceed under the broader statutory and regulatory powers of CASA and applicable aviation safety legislation and regulations, which are not reproduced in this Directive text.

• Practical enforcement implications. Because the Directive binds operators of affected Australian-registered aircraft, failure to comply with an AD can have operational consequences: CASA typically exercises oversight through surveillance, audits, airworthiness certificate control, and continuing airworthiness processes. Leases, insurers, and registries will typically require compliance with ADs; non-compliance can affect airworthiness certification and commercial operations. However, the Directive’s text does not specify those outcomes. The AD does note FAA AD 2005-16-08 and FAA AMOCs, which can be used to show compliance equivalence where accepted (Requirement; Note 2).

• Conformity with ASB/SB as evidence. Because the AD links compliance to the ASB Accomplishment Instructions and to the SB for terminating action, completed maintenance records showing work performed to those documents are the principal documentary evidence to demonstrate compliance with the Directive (Requirement).

In short, the AD mandates specific maintenance and modification actions and sets enforceable timelines, but the supplied text does not state explicit penalties or enforcement procedures. The practical enforcement environment will be informed by CASA’s broader regulatory powers and by airworthiness certification processes, while compliance is demonstrated through adherence to the referenced ASB and SB documentation.

The Directive interacts with and references several instrument types and regulatory concepts. The text supplied makes specific cross-references to FAA instruments and to Boeing service documents, and it frames acceptable methods of compliance by reference.

• Interaction with manufacturer service documents. The Directive depends on Boeing Alert Service Bulletin (ASB) 717-35A0003 Revision 1 to define both applicability and the technical method for replacement and testing. It also references Boeing Service Bulletin (SB) 717-35-0004 (original issue dated 10 January 2006 or Revision 1 dated 3 May 2006) as the document describing the optional terminating modification. The AD therefore places service bulletins at the centre of compliance, integrating manufacturer instructions into regulatory requirements (Applicability; Requirement).

• Interplay with FAA Airworthiness Directive. The AD explicitly references FAA AD 2005-16-08 Amdt 39-14213 (Note 2). It also states that "Later revisions of the ASB 717-35A0003, Revision 1, approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2005-16-08, are considered acceptable for compliance with the equivalent Requirements of this Directive" (Requirement). That indicates CASA’s acceptance, in the instrument’s terms, of FAA-approved AMOCs for the ASB as an equivalent compliance pathway. The AD therefore creates a cross-recognition mechanism between CASA’s directive and FAA approvals, for the narrowly specified documents and revisions.

• Dependence on non-statutory technical materials. The AD does not itself contain the technical steps; instead, it mandates work "in accordance with the Accomplishment Instructions of ASB 717-35A0003, Revision 1". That means the legal requirement in the AD is to follow the non-statutory, manufacturer-authored instructions contained in the ASB. Compliance therefore requires access to those technical materials and accurate application of them.

• Relationship to certification and continuing airworthiness regimes. While the AD text does not reproduce wider legislative instruments, as a CASA AD it functions within the broader Australian aviation regulatory system, where airworthiness directives operate as continuing airworthiness obligations. The AD’s effective dates and requirements implicitly affect airworthiness status until complied with, and they interact with maintenance release, flightworthiness directives, and certificate-holding requirements. Those broader regulatory instruments and powers are not reproduced in the AD text supplied.

• Acceptable pre-effective compliance. The AD expressly accepts "Replacements and tests accomplished before the effective date of this Directive in accordance with ASB 717-35A0003, dated 19 November 2004" as compliance (Requirement). That creates a temporal interaction between the earlier ASB work and this AD’s obligations.

• Deference to FAA AMOCs creates an international regulatory linkage. By stating that FAA-approved AMOCs for later ASB revisions "are considered acceptable for compliance with the equivalent Requirements of this Directive," the AD establishes a mechanism for incorporating FAA determinations into CASA’s compliance framework, at least for the specific ASB and FAA AD referenced. That shapes how operators with internationally managed fleets or FAA-based engineering approvals might meet CASA’s requirement.

The AD therefore integrates manufacturer technical material and an FAA AD framework into an Australian regulatory requirement. It binds operators to actions described in external documents and accepts certain FAA approvals as equivalent compliance, subject to the documents and revisions specified. The Directive’s structure means that resolving questions about scope, affected aircraft, and exact procedures will require consulting the ASB, the SB, and the FAA AD and its AMOC approvals as referenced.

The AD text supplies explicit amendment and original-issue dates and describes the evolution of the requirement in functional terms. The documented history in the supplied text is as follows.

• Original Directive. The AD states that "The original issue of this Directive became effective on 29 September 2005" (Background). The original issue required repetitive replacing and testing of a relay in the passenger oxygen release system in the forward cabin, responding to FAA reports of failed relays that could prevent mask deployment in rapid decompression or depressurisation events (Background).

• Amendment documented herein. The instrument before the reader is labelled "AD/B717/18 Amdt 1" and the text states "This Amendment becomes effective on 27 August 2009" (top table; Background). The AD is signed by James Coyne, Delegate of the Civil Aviation Safety Authority, and dated 30 June 2009 (signature block), indicating the delegate’s sign-off date and the official effective date for the amendment.

• Functional change introduced by the amendment. The Background paragraph summarises the difference between the original Directive and the Amendment: "The original issue of this Directive required the repetitive replacing and testing a relay in the passenger oxygen release system in the forward cabin. This Amendment continues the repetitive inspection requirements but introduces an optional termination action to the repetitive inspections." In other words, the Amendment retains the recurring replacement/testing regime but adds an optional terminating modification described in Boeing SB 717-35-0004 as a way to end the recurring obligation (Background; Requirement).

• Service bulletin revisions and FAA AMOC recognition. The Amendment explicitly expands acceptable compliance methods by stating that "Later revisions of the ASB 717-35A0003, Revision 1, approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2005-16-08, are considered acceptable for compliance with the equivalent Requirements of this Directive" (Requirement). This reflects a change in how later ASB revisions, if FAA-approved as AMOCs, are treated under the AD.

• Prior compliance acceptance. The Amendment preserves continuity by stating that "Replacements and tests accomplished before the effective date of this Directive in accordance with ASB 717-35A0003, dated 19 November 2004, are acceptable for compliance with Directive" (Requirement). That means operators who complied with the earlier ASB will not need to reperform the same work to meet the AD’s requirement.

• Notes about SB revision scope. The AD includes Note 1, which records that "SB 717-35-0004 Revision 1 requires more work to be accomplished on Group 2 and 3 aeroplanes." The presence of that note indicates the Amendment contemplates different workloads for different groups under the SB revision.

The Amendment therefore represents a targeted modification of the original 2005 Directive: keeping the mandated recurring replacement and testing but adding an optional terminating modification and clarifying acceptance of certain FAA-approved later ASB revisions. The Amendment’s effective date is 27 August 2009, with the delegate’s signing recorded as 30 June 2009. The AD supplies no further historical amendments or subsequent revisions in the text provided.

The text of AD/B717/18 Amdt 1 as supplied does not include any references to litigation, judicial review, enforcement proceedings, or court decisions. There are no cases, appeals, or tribunal matters mentioned in the instrument. The document is an administrative regulatory instrument issued by the Civil Aviation Safety Authority, carrying operative requirements and effective dates, and it records the factual safety rationale and service-document references that underpin the mandatory actions (Background; Requirement; Compliance). However, the Directive itself contains no litigation history, and no judicial or administrative proceedings are reported or annexed to the text provided.

Where disputes about an AD’s validity, scope, or enforcement might arise, the AD text here does not record any such matters. The instrument does cite FAA AD 2005-16-08 and references FAA AMOCs, but it does not place those references in a contested or litigated context (Requirement; Note 2). In short, the supplied AD contains no litigation history and does not indicate any legal challenges, appeals, or case law relating to its content.

If a party needs to determine whether litigation or administrative review has occurred in relation to this Directive, or whether enforcement actions have been taken, they would need to consult external records, CASA enforcement logs, or court and tribunal databases, none of which are reproduced in or referenced by the AD text supplied.

The Directive’s brevity and its reliance on external service documents create several practical pitfalls for operators and maintenance organisations. The following are concrete risks and traps that emerge from the text.

• Applicability is external to the AD. The AD identifies affected aeroplanes by reference to ASB 717-35A0003 Revision 1. The AD text does not itself list serial numbers or group definitions, so an operator must consult the ASB to determine whether a particular aircraft is in scope and which group it belongs to (Applicability). Misreading or failing to consult the ASB could lead to incorrect assumptions about applicability and timing.

• Group definitions matter for timing and workload. The AD sets different initial compliance timings for Group 1 and Group 2 aeroplanes, and it cross-references SB 717-35-0004 "as applicable by aircraft group identified in the SB" for terminating action (Compliance; Requirement). Because the AD text does not reproduce group definitions, operators must match their aeroplanes to the ASB and the SB group tables. Getting the group identification wrong will produce incorrect scheduling or omission.

• Prior work acceptance only for specific ASB version. The AD accepts replacements and tests done before the AD’s effective date if performed "in accordance with ASB 717-35A0003, dated 19 November 2004" (Requirement). That acceptance is limited to the earlier ASB version specified. Work done against any different or informal procedure without alignment to that ASB may not be accepted as compliant.

• AMOC dependence is narrow. The AD accepts "Later revisions of the ASB 717-35A0003, Revision 1, approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2005-16-08" as acceptable for compliance (Requirement). That acceptance is contingent on FAA approval as an AMOC to FAA AD 2005-16-08; it does not automatically accept any later ASB revision absent that FAA AMOC designation. Operators must verify FAA AMOC status for later ASB revisions before relying on them for compliance.

• Optional terminating action may require more work depending on SB revision. Note 1 records that "SB 717-35-0004 Revision 1 requires more work to be accomplished on Group 2 and 3 aeroplanes." That means electing the terminating modification could require additional labour or parts for certain groups. Operators should not assume that the terminating action is uniform across groups.

• Timing language potentially confusing for Group 2. The Group 2 compliance timing is phrased as "Before the accumulation of 3,100 total flight cycles, or within six months after the effective date of the original issue of this Directive, whichever is later, and thereafter at intervals not to exceed 3,100 flight cycles" (Compliance). In practice, operators must calculate whether the "before the accumulation of 3,100 total flight cycles" condition or the "within six months" deadline applies, and ensure maintenance programmes reflect the later of the two. Mistakes in cycle counting or in interpreting "whichever is later" could lead to late compliance.

• Recordkeeping and proof of compliance hinge on ASB/SB documentation. Because the AD requires work "in accordance with the Accomplishment Instructions of ASB 717-35A0003, Revision 1," evidence of compliance will be the maintenance records showing the work done in accordance with the ASB, and any FAA AMOC approvals relied upon (Requirement). Poor recordkeeping or failure to cite the exact ASB/SB revision used could complicate inspections or audits.

• No explicit alternative compliance pathway described. The AD does not describe a CASA AMOC or equivalent process in the text provided, and it defers to FAA AMOCs for later ASB revisions. Operators lacking FAA AMOCs or unwilling to adopt the SB terminating modification may be constrained to the recurring replacement/testing schedule until a CASA-accepted alternative is available.

• Interaction with leasing and international operators. The AD’s acceptance of FAA AMOCs might be helpful for fleets operating across registers, but reliance on FAA approvals requires verification of the specific AMOC approvals. Lessors and lessees should ensure contractual compliance clauses account for differing national ADs and acceptable AMOCs, because the AD as written ties compliance to specific external approvals and documents.

• No penalties detailed in the AD text. The AD contains no explicit penalty regime; enforcement and consequences for non-compliance are not set out in the instrument itself (Penalties and enforcement). Operators should not interpret this absence as permitting non-compliance; rather, they should recognise that enforcement mechanisms operate through the wider regulatory framework.

These "gotchas" arise directly from the AD’s structure: heavy reliance on external documents, group-based differentiation left to the ASB/SB, conditional acceptance of prior work and later ASB revisions, and concise compliance language that requires precise interpretation and accurate maintenance scheduling.

The AD ties compliance to specific service documents and prescribes timing by aircraft group. The following practical compliance checklist sets out the steps an operator should take, strictly based on the Directive text and the documents it references.

1. Determine applicability via ASB 717-35A0003 Revision 1.

   • Obtain Boeing Alert Service Bulletin 717-35A0003 Revision 1, dated 7 June 2005.
   • Using the ASB, verify whether each McDonnell Douglas Model 717-200 aeroplane in your fleet is identified as affected (Applicability). Do not rely on the AD text alone for serial-number or group identification.

2. Establish aircraft group.

   • From the ASB (and if necessary SB 717-35-0004), determine which group (Group 1, Group 2, Group 3 if applicable) each affected aeroplane belongs to, since initial compliance timing and the scope of the terminating modification depend on group identity (Applicability; Requirement; Note 1).

3. Review prior maintenance to identify acceptable pre-AD compliance.

   • If replacements and tests were performed before the Directive’s effective date, confirm whether they were done "in accordance with ASB 717-35A0003, dated 19 November 2004." If so, those works are explicitly acceptable as compliance under the AD (Requirement).

4. Schedule and perform the replacement and test work per the ASB.

   • Follow the Accomplishment Instructions in ASB 717-35A0003 Revision 1 to "Replace the relay in the passenger oxygen release system in the forward cabin with a new relay and test for proper operation" (Requirement).
   • Ensure maintenance engineers use the exact revision of the ASB identified unless an FAA-approved later revision is being relied upon as an AMOC (see step 6).

5. Apply the initial compliance timing by group.

   • For Group 1: perform the first replacement/test "within six months after the effective date of the original issue of this Directive" and thereafter at intervals "not to exceed 3,100 flight cycles," until the aircraft is modified per SB 717-35-0004 (Compliance).
   • For Group 2: perform the first replacement/test "before the accumulation of 3,100 total flight cycles, or within six months after the effective date of the original issue of this Directive, whichever is later," and thereafter at intervals "not to exceed 3,100 flight cycles," until modification per SB 717-35-0004 (Compliance).
   • Document calculations of flight cycles and dates to demonstrate adherence to the "whichever is later" timing rule for Group 2.

6. Consider FAA-approved later ASB revisions only if an FAA AMOC exists.

   • The AD accepts "Later revisions of the ASB 717-35A0003, Revision 1, approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance to FAA AD 2005-16-08" as acceptable for compliance with the equivalent requirements (Requirement).
   • If you intend to rely on a later ASB revision, obtain confirmation of FAA AMOC status for that ASB revision, and retain documentary proof of the FAA AMOC approval as part of the maintenance record.

7. Decide whether to adopt the optional terminating modification in SB 717-35-0004.

   • Obtain Boeing Service Bulletin SB 717-35-0004, original issue dated 10 January 2006 and Revision 1 dated 3 May 2006.
   • Determine applicability of the SB by aircraft group as identified in the SB. Note 1 records that Revision 1 requires more work on Group 2 and Group 3 aeroplanes.
   • If electing the terminating modification, perform the modification in accordance with the SB issue/revision that applies to your aircraft group. After the modification is accomplished, the AD indicates that the repetitive inspections/replace-and-test cycle are terminated for that aeroplane (Requirement).

8. Maintain contemporaneous records.

   • Record the exact ASB or SB revision used, the date the replacement and test were performed, the flight-cycle count at the time of works, and any FAA AMOC approvals relied upon.
   • If earlier work from ASB dated 19 November 2004 is being relied upon, retain the maintenance records showing that the work conformed to that ASB.

9. Update maintenance programmes and manuals.

   • Incorporate the recurring replacement/test intervals of not more than 3,100 flight cycles into maintenance planning until the terminating modification is installed for the relevant aeroplanes.
   • For Group 2, ensure the initial event is scheduled consistent with the "before the accumulation of 3,100 total flight cycles, or within six months... whichever is later" rule.

10. Coordinate with lessors, insurers, and registries as necessary.

    • Notify lessors or financiers where requisite by lease covenants, and ensure the AD compliance is recorded in continuing airworthiness records that affect airworthiness certificates and lease compliance.

11. Verify regulatory status and effective dates.

    • The Amendment became effective on 27 August 2009, with the original AD effective on 29 September 2005 (Background). Ensure compliance scheduling reflects which effective date window applied to your aircraft when the AD was issued and when initial compliance became due.

12. If in doubt, consult CASA or an authorised engineering authority.

    • For questions about applicability, the acceptability of a particular ASB/SB revision, or reliance on FAA AMOCs, verify with CASA or an appropriately authorised maintenance/engineering organisation. The AD itself references FAA AMOCs and service documents; any alternative compliance approach should be validated with the regulator.

Following these steps will align an operator’s practices with the precise requirements and options the Directive sets out: replacement and testing per ASB 717-35A0003 Revision 1, recurring intervals not to exceed 3,100 flight cycles by group, acceptance of specific prior ASB work, conditional acceptance of FAA-approved later ASB revisions as AMOCs, and an optional terminating modification via SB 717-35-0004 where applicable.