The Directive contains several narrowly worded provisions and cross-references that create potential compliance pitfalls. These are drawn from the text and should be checked carefully when determining whether a particular aircraft or past action satisfies the Directive.
Narrow applicability by SB identification: Applicability is “Model 717-200 aeroplanes, as identified in Boeing Service Bulletin (SB)717-28-0007, Revision 1, dated 23 September 2003” (Applicability). That wording ties applicability to the list contained within the SB, not merely to the generic model designation. The practical implication is that an aeroplane operator must consult SB 717-28-0007 Rev 1 to confirm whether a specific airframe is listed. Assuming all Model 717-200 aeroplanes are covered without checking the SB could be incorrect.
Completeness requirement for the SB actions: The Requirement mandates accomplishing “all of the actions specified in SB 717-28-0007, Revision 1” (Requirement). Partial compliance or selective application of SB procedures does not meet the Directive’s wording. Readers should note that the Directive’s text does not allow for executing only parts of the SB: the full sequence of actions must be completed.
Conditional acceptance is limited and procedural: The Directive accepts earlier work done under the 22 August 2002 SB only if a leak check is performed in accordance with AMM Task 28-22-28-700-801 (Requirement). Merely having executed the older SB before the effective date is not sufficient; the specified AMM leak test is an explicit and necessary condition.
Later SB revisions are acceptable only with FAA AMOC to a named FAA AD: The Directive accepts later SB revisions solely when those revisions have been “approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2008-01-12” (Requirement). If a later SB revision exists but has not been approved by the FAA as an AMOC to FAA AD 2008-01-12, the Directive’s text does not accept it. The conditionality is specific: it ties acceptance to FAA AMOC approval to a particular FAA AD, not merely to generic FAA acknowledgement.
Cross-reference complexity: The Directive contains a note that “FAA AD 2008-02-12 Amdt 39-15342 refers” (Requirement/Note). That reference may require readers to check multiple FAA AD documents (FAA AD 2008-01-12 and FAA AD 2008-02-12) to understand the FAA-side compliance landscape. The Directive itself does not restate the FAA AD provisions, meaning users must consult those FAA documents externally to confirm AMOC status or related technical content.
Compliance time window: The compliance deadline is “within 78 months after the effective date of this Directive” (Compliance). The effective date is “13 March 2008” (Compliance). The long numeric window could be misread as permissive; however, the Directive sets that as the firm compliance period. Users should calculate the precise calendar deadline and ensure documentation and proofs of work satisfy the Directive’s requirement within that timeframe.
Documentation expectations implicit but not enumerated: The Directive prescribes specific SB and AMM tasks for the work and the leak test but does not list what documentary proof of compliance must look like. The Requirement’s phrasing , mandating adherence to specified SB and AMM tasks , implicitly expects that work will be performed and recorded to those procedural standards, but the Directive does not itself specify recordkeeping formats, certification stamps, or acceptance procedures.
No internal enforcement language: Because the Directive contains no explicit enforcement or penalty provisions, parties cannot rely on the Directive text alone to determine enforcement mechanisms or remedial steps for non-compliance. That gap can be a source of uncertainty about consequences; the Directive itself provides no process details.
Signature and issuing delegate timing: The signature block shows the Directive’s issuance on 29 January 2008 and an effective date of 13 March 2008 (signature block; Compliance). Users should note the short interval between signature and effective date in case any immediate actions were taken in that timeframe.
In short, the core “gotchas” are the SB-based applicability list (not simply “all 717-200s”), the requirement to perform “all” SB actions, the exact leak-test condition for prior work, the requirement that later SB revisions carry a specific FAA AMOC to a named FAA AD, and the lack in the text of explicit documentary or enforcement procedures. Each of these is explicitly or implicitly present in the Directive text and can lead to unsuccessful compliance if not checked against the precise wording.