AD/B737/288 - Driessen Galleys

An Airworthiness Directive is a legally enforceable notice issued under the Civil Aviation Act and associated regulations, requiring an aircraft owner or operator to inspect, modify, or take other action to maintain the aircraft’s airworthiness. AD/B737/288 is one such directive, adopted by CASA to address a specific safety risk identified in US Federal Aviation Administration testing. The directive is not a standalone statute but sits within a broader framework of continuing airworthiness management; its legal force derives from the obligation to keep an aircraft in a condition that complies with all applicable airworthiness directives.

The central physical concept is the “spiral protective wrapping” of electrical cables inside aircraft galleys. This wrapping is a material applied around bundles of electrical wires to protect them from abrasion and environmental damage. The FAA testing found that the wrapping in certain galleys and closets had unacceptable flammability properties, meaning it could ignite or propagate a fire if an electrical arc or spark occurred. The directive therefore mandates replacement with wrapping that satisfies a defined flammability requirement. The replacement must be performed in accordance with specified service information - the detailed instructions issued by Boeing and approved by the FAA or CASA.

The directive introduces several distinct categories of service information. Table 1 lists the primary service bulletins that define both the part numbers to be inspected and the method of replacement. Table 2 lists earlier revisions of the same service bulletins; work performed using those earlier revisions before the directive’s effective date is recognised as compliant. This “grandfathering” provision avoids requiring operators to re‑do work already accomplished to a prior specification, provided that prior specification aligns with the original FAA AD (2006‑12‑06). Additionally, later revisions of the service bulletins that have received FAA AMOC approval are acceptable. This recognises that approved modifications to the original procedures remain valid, but the operator must verify that the FAA has actually issued an AMOC - the mere existence of a later revision is not enough.

The term “galley” is defined for the purposes of this directive to include the terms “buffet” and “closet” as used in the referenced service information. This prevents any narrow reading of the scope; if a unit functions as a galley, buffet or closet and is from Driessen or Showa, the directive applies. The part number check is the gatekeeper: only units with part numbers listed in the applicable service bulletin require action. This risk‑based approach means that not every galley on an affected aeroplane needs rectification, only those confirmed to have the suspect part number.

The compliance period of 72 months is unusually long for an airworthiness directive. It reflects the lower immediate risk of a fire initiation from the cable wrapping, balanced against the practical burden of scheduling the work during routine heavy maintenance checks. The long lead time also gives operators flexibility to incorporate the work into existing maintenance programs without grounding aircraft prematurely. However, the directive does not allow for extensions; non‑compliance on 3 August 2012 would render the aircraft un‑airworthy.

The primary group affected is operators of Boeing 737 series aeroplanes. The directive specifically names Model 737‑300, ‑400, ‑500, ‑700 and ‑800 series aeroplanes. These models cover a large portion of the worldwide 737 Classic and Next Generation fleets. Australian operators - including major airlines, regional carriers, charter operators, and lessors - that have any of these models in their fleet are directly captured. The directive applies regardless of whether the aircraft is registered in Australia or operated under an Australian air operator’s certificate, because CASA airworthiness directives extend to Australian‑registered aircraft and to foreign‑registered aircraft operated by Australian operators.

The directive also affects maintenance organisations. Approved maintenance organisations (AMOs) that perform heavy maintenance or component work on the affected Boeing 737 models must be familiar with the service bulletins referenced in Table 1 and Table 2. They need to have the correct replacement materials and tooling, and their engineers must be trained to accomplish the cable wrapping replacement. Because the work involves electrical cable bundles inside galleys, it may require coordination with interior refurbishment or galley shop visits. The directive does not require any specific certification of the replacement wrapping beyond being “shown to meet certain flammability testing requirements”; the service bulletins themselves will specify the required material specifications and test standards.

Suppliers and manufacturers are indirectly affected. Driessen Aircraft Interior Systems and Showa Aircraft Industries, as the original equipment manufacturers of the affected galleys, may be required to provide replacement spiral wrapping kits or to support Boeing in issuing service bulletins. Boeing is the source of the service information; any revisions or AMOC approvals involve Boeing as the design approval holder. The directive’s provision that later service bulletin revisions approved by the FAA as AMOC are acceptable gives Boeing an avenue to update the method or materials without requiring a new CASA directive.

Lessors and financiers of affected aeroplanes must also ensure that their leases and loan agreements require compliance with all applicable airworthiness directives. A failure to complete AD/B737/288 by the 3 August 2012 deadline could render an aircraft un‑airworthy, grounding it and potentially triggering default under a lease or financing agreement. The long compliance period should give lessors time to schedule the work, but the cost of the replacement remains an operating expense that must be borne by the operator unless the lease provides otherwise.

Passengers and crew are the ultimate beneficiaries of reduced fire risk, but they bear no direct legal obligation. Insurers may also be interested: compliance with airworthiness directives is typically a condition of hull and liability insurance, and non‑compliance could void coverage in the event of an incident involving electrical arcing or fire in a galley.

The directive imposes two primary duties. The first duty is to conduct an inspection - or a review of maintenance records - to identify whether any galley part number installed on the aeroplane matches one of the part numbers listed in the applicable service information from Table 1. The duty extends to all galleys on the aircraft; because the directive defines “galley” to include buffet and closet, the inspection must cover those units as well. The operator may choose between a physical inspection of the galleys or a records review, but only if the part numbers can be positively determined from the records. If the records are incomplete or ambiguous, a physical inspection is necessary.

The second duty, which arises only if a listed part number is found, is to replace the spiral protective wrapping of the electrical cables of that galley with new wrapping that meets the flammability testing requirements. The replacement must be performed in accordance with the applicable service bulletin listed in Table 1. This duty is not discretionary; if the listed part number is present, the wrapping must be replaced. The operator has the right to use a previously accomplished replacement as compliance, but only if that replacement was performed using the exact earlier revisions listed in Table 2, with the dates specified. If the operator used a different revision or method, it does not qualify as previous accomplishment under this directive. However, the operator may apply for an alternative method of compliance or use a later FAA‑approved AMOC, as recognised in the directive’s provision that later revisions of Table 1 service bulletins approved by the FAA as AMOC to FAA AD 2006‑12‑06 are acceptable.

The operator has a right to rely on the fact that if no listed part number is found after inspection or records review, no further action is required. This is a binary outcome; the operator does not need to file any report or notify CASA of a negative finding. The directive does not require any specific record‑keeping beyond normal maintenance documentation, but as a matter of good practice, operators should document the inspection and the part numbers checked, to demonstrate compliance in the event of an audit.

The compliance period of 72 months gives the operator significant scheduling flexibility. The operator may choose to accomplish the inspection and any replacement at the next convenient heavy maintenance check, or to defer it to near the deadline. However, deferring to the last moment carries the risk that parts or capacity may become constrained if many operators leave the work to the same final window.

The directive itself does not specify penalties, but non‑compliance with an airworthiness directive is a breach of the continuing airworthiness obligations under the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations 1998 (CASR). Operating an aircraft that does not conform to its approved type design or is not in a condition for safe operation can result in the aircraft being grounded, suspension or revocation of the air operator’s certificate, and civil penalties. Under CASR Part 42 (Continuing Airworthiness), an operator must ensure that all applicable airworthiness directives are complied with within the required time. Failure to do so may constitute an offence carrying a maximum penalty of 50 penalty units (currently AUD 10,000) for an individual, and higher for a body corporate. More seriously, a deliberate or reckless failure could attract criminal liability under the Act.

CASA has enforcement powers that include issuing infringement notices, initiating proceedings in the Federal Court, and seeking injunctions to prevent an un‑airworthy aircraft from flying. The practical enforcement mechanism is through the annual or continuing airworthiness inspection; if an aircraft’s maintenance records do not show compliance with this directive by the cutoff date, the aircraft will not be issued a Certificate of Release to Service and may be grounded indefinitely. The cost of grounding is typically far greater than any fine, which creates a strong economic incentive for operators to comply.

The directive’s reference to FAA AD 2006‑12‑06 and FAA‑approved AMOCs indicates a degree of international harmonisation. If an operator uses a later service bulletin revision approved by the FAA as an AMOC to the FAA AD, that is accepted for compliance with this CASA directive. However, the operator must still ensure that the AMOC approval is current and that the work is performed in accordance with the approved revision. The operator also bears the burden of proof if audited: the maintenance records must clearly show the service bulletin revision used and the basis for its acceptance. The directive does not provide an avenue for an Australian operator to apply directly to CASA for an AMOC; it only recognises FAA approvals. This may create a problem if a later revision is not FAA‑approved but is otherwise technically equivalent - the operator would need to seek a separate CASA exemption or AMOC.

This directive is issued under the authority of the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations, which give CASA the power to issue airworthiness directives that are mandatory for Australian‑registered aircraft and for foreign aircraft operated by Australian operators. It coexists with FAA AD 2006‑12‑06 (Amendment 39‑14631), from which it is derived. The directive expressly references the FAA AD and allows FAA‑approved AMOCs to later service bulletin revisions, creating a direct bridge between the two jurisdictions. In practice, an aircraft that complies with the US AD will also comply with the Australian AD, provided the maintenance is performed within the same compliance period.

The directive interacts with other airworthiness directives applicable to Boeing 737 aircraft. For example, there may be separate ADs requiring modifications to galley structures, electrical bonding, or fire extinguishing systems. The galley wrapping replacement must be done without conflicting with those other ADs, but the directive does not address potential interactions. The operator and its maintenance organisation must check for cumulative effects and ensure that the work under AD/B737/288 does not inadvertently violate another directive.

Under the CASR framework, airworthiness directives are part of the continuing airworthiness requirements. They are separate from but complementary to maintenance manuals, inspection programs, and component overhaul schedules. Compliance with this directive becomes part of the aircraft’s maintenance history and must be recorded in the logbook or equivalent. The directive does not affect the aircraft’s type certificate; the modification to the galley wiring wrapping is a minor design change that does not require a supplemental type certificate, as it is performed in accordance with an FAA‑approved service bulletin.

For leased aircraft, the directive interacts with the leasing contract and the lessee’s obligation to maintain airworthiness. Most aircraft leases require the lessee to comply with all applicable airworthiness directives. The 72‑month compliance period should give both parties adequate time to plan the work, but the cost allocation will depend on the lease’s maintenance reserve provisions. If the work is considered a “life‑limited part” replacement or a mandatory modification, it may be chargeable to the lessee as a maintenance cost. The directive does not regulate such commercial arrangements.

The directive also interacts with international standards under the Convention on International Civil Aviation. Australia is a signatory, and CASA’s adoption of FAA findings supports the mutual recognition of airworthiness approvals. Operators of Australian‑registered aircraft that fly internationally must comply with the airworthiness directives of the state of registry, so compliance with this AD is mandatory regardless of where the aircraft operates. Overseas maintenance organisations performing the work must be authorised by CASA or an equivalent authority to certify the work.

The text of AD/B737/288 does not contain any amendment history for the directive itself. The directive is presented as a single instrument, signed by the delegate of the CASA CEO on 20 June 2006, with an effective date of 3 August 2006. There is no indication of prior versions or subsequent amendments on the face of the document. However, the directive incorporates by reference service information that has been revised over time. Table 1 lists Boeing Service Bulletin 737‑25‑1439 at Revision 3 (11 November 2004), while Table 2 lists earlier versions of the same bulletin at Revision Original (15 March 2001), Revision 1 (2 August 2001), and Revision 2 (19 December 2001). This indicates that the underlying technical instructions evolved over several years before the CASA directive was issued, but the directive itself was not revised during that period.

The directive’s provision that later revisions of the Table 1 service bulletins, approved by the FAA as an AMOC to FAA AD 2006‑12‑06, are acceptable for compliance means that the directive’s requirements can change without a formal amendment to the AD itself. This is an efficient regulatory mechanism: if the manufacturer issues Revision 4 of the service bulletin and the FAA approves it as an AMOC, operators may use it immediately without waiting for CASA to publish a new directive. However, this also creates a potential trap: the operator must stay informed about FAA AMOC approvals and cannot rely solely on the revision levels listed in Table 1. The directive does not require CASA to publish each FAA AMOC; the operator bears the responsibility of checking the FAA’s AD docket.

The directive was published in the CASA Airworthiness Bulletin and appears as AD/B737/288. There is no published history of amendments to this specific AD on the CASA website as of the document’s date. It is likely that the directive has not been superseded or revoked, but an operator should verify the current status through the CASA online database. The directive’s compliance date of 3 August 2012 has long passed, so any aircraft still in service must have had the work completed decades ago. Nevertheless, the AD remains technically in effect as a record of the requirement, and any subsequent operator of an affected aircraft should check that the work was indeed accomplished.

The source text contains no mention of any litigation. Because AD/B737/288 is a specific directive aimed at a narrow technical issue - replacement of galley wire wrapping - it is unlikely to have generated significant case law. Airworthiness directives are generally challenged only on procedural grounds or if an operator disputes the factual basis for the alleged safety risk. The background section of this directive notes that the FAA had received test results and reports from the manufacturer indicating unacceptable flammability properties. If an operator wanted to challenge the directive, it would need to contest either the methodology of the flammability tests or the causal link between the wrapping and fire propagation. No such challenge is recorded in the document.

The directive incorporates the FAA’s findings, and Australian courts typically afford substantial deference to the technical expertise of airworthiness regulators. Under the Administrative Appeals Tribunal Act 1975, an operator could theoretically seek merits review of a CASA decision to issue a directive, but the Administrative Appeals Tribunal would be unlikely to substitute its own engineering judgment for that of the regulator unless the directive was manifestly unreasonable. No case law on this specific directive is cited, and searches of legal databases would be unlikely to find any.

The reference to FAA AD 2006‑12‑06 and AMOCs suggests that litigation in the United States could indirectly affect compliance under the Australian directive. For example, if the FAA were to revoke an AMOC to its AD due to a procedural flaw, that would affect the acceptability of that AMOC under the CASA directive. But such events are speculative and not recorded in the source.

Given the directive’s age, any litigation would have occurred within the limitation period following the 3 August 2012 compliance deadline. The absence of any mention in the source suggests that the directive was complied with without significant legal contest. This is typical of prescriptive airworthiness directives where the cost of compliance is modest relative to the cost of litigation and the risk of grounding.

Several details in the directive warrant close attention. First, the definition of “galley” is explicitly stated to include the terms “buffet” and “closet” that are used in the referenced service information. Operators may be tempted to treat a unit called a “buffet” or “closet” as outside the scope of the directive. The directive expressly rules this out. Any unit that is a galley, buffet, or closet supplied by Driessen or Showa must be included in the inspection.

Second, the directive allows a review of aeroplane maintenance records as an alternative to physical inspection, but only if the part numbers can be positively determined from that review. If the records are incomplete, illegible, or do not record the specific part number of the galley, then a physical inspection is required. Records review is not a shortcut - it is only permissible if it yields the same certainty as a physical look. The operator bears the risk that an auditor may consider the records insufficient and deem the inspection incomplete.

Third, the “previous accomplishment” provision in Table 2 is limited to exact revision levels and dates. Work done using Revision 2 of Service Bulletin 737‑25‑1439 dated 19 December 2001 is acceptable; work done using the same revision but a different date or a later revision that does not have FAA AMOC approval is not. Operators who performed the work using a later revision before the directive’s effective date must check whether that revision has since received FAA AMOC approval; otherwise, they may need to re‑do the work.

Fourth, the directive states that later revisions of the Table 1 service bulletins, approved by the FAA as an AMOC to FAA AD 2006‑12‑06, are considered acceptable for compliance with the equivalent requirements of this directive. This is a cross‑reference that requires the operator to monitor FAA actions. The directive does not list which revisions have been approved. An operator using a later revision that is not FAA‑approved is not in compliance, even if the revision is better or safer. The operator must obtain documentation of the FAA AMOC.

Fifth, the compliance period is 72 months from the effective date of 3 August 2006. That date has passed, but the directive remains in effect for any aircraft that was not complied with. An aircraft that missed the deadline would be un‑airworthy and would require retrospective compliance, possibly with additional penalties. The long period may create a false sense of security; operators should have scheduled the work well before the deadline to avoid last‑minute parts or labour shortages.

Sixth, note that the directive says “Instead of inspecting the galleys to determine if the P/Ns are installed, a review of aeroplane maintenance records is acceptable if the P/Ns can be positively determined from that review.” This means the records review is only an alternative for the inspection requirement. It does not substitute for the replacement requirement if a listed P/N is found. The replacement must still be performed.

Finally, the directive does not allow an Australian operator to apply directly for an AMOC. It only accepts FAA‑approved AMOCs. Operators who wish to use a different method or a later revision not yet approved by the FAA must seek a separate exemption from CASA under CASR Part 11, which is a separate process with its own delays and costs.

Compliance with AD/B737/288 involves a structured process that begins with identifying which aeroplanes in the operator’s fleet are subject to the directive. The operator should compile a list of all Boeing 737‑300, ‑400, ‑500, ‑700 and ‑800 series aeroplanes on its Australian register or operated by it, and note the model and whether each is equipped with galleys from Driessen or Showa. If any of those models do not have Driessen or Showa galleys, they are not affected. For the affected aircraft, the operator must then determine the part numbers of all galleys, buffets and closets installed.

The operator can satisfy the first requirement either by inspecting each galley physically or by reviewing the aircraft’s maintenance records. If using records, the operator must ensure the records contain the part numbers of each galley unit. The records must be complete and unambiguous; if any galley’s part number is missing or uncertain, a physical inspection is required for that unit. Once the part numbers are known, the operator compares them against the list of part numbers in Boeing Service Bulletin 737‑25‑1438 (for Classic models) or 737‑25‑1439 (for Next Generation models), Revision 1 for the former and Revision 3 for the latter. If a galley’s part number is not listed, no further action is required for that unit. If it is listed, the operator must proceed to Requirement 2.

For each galley with a listed part number, the operator must replace the spiral protective wrapping of its electrical cables. The replacement must be performed in accordance with the applicable service bulletin listed in Table 1 - that is, Revision 1 of 737‑25‑1438 or Revision 3 of 737‑25‑1439. The operator may substitute a later revision of that service bulletin if the FAA has approved that revision as an AMOC to FAA AD 2006‑12‑06. The operator must obtain written evidence of the FAA’s approval and keep it with the maintenance records. If the operator previously replaced the wrapping before 3 August 2006 using earlier revisions listed in Table 2, that work is acceptable and the replacement does not need to be repeated. The earlier revisions are: for 737‑25‑1438: Original dated 15 March 2001; for 737‑25‑1439: Original (15 March 2001), Revision 1 (2 August 2001), and Revision 2 (19 December 2001). Any other prior work, including work using a later revision without FAA AMOC approval, is not acceptable and must be re‑done.

The work itself must be carried out by an approved maintenance organisation (AMO) with the appropriate ratings for Boeing 737 airframe and electrical systems. The AMO will need to obtain the correct service bulletin, source the replacement spiral wrapping material (which must meet the flammability requirements stated in the bulletin), and perform the replacement in a safe and approved manner. After completion, the AMO must issue a Certificate of Release to Service, recording the work and the applicable service bulletin revision.

The operator must also update its continuing airworthiness records to show compliance with this directive. A record should include the aircraft registration, the galley part numbers checked, the inspection method (records review or physical), the service bulletin used, the date of the replacement, and any FAA AMOC documentation. This record will be examined during the annual continuing airworthiness inspection or if the aircraft is sold or leased. Finally, the operator should set a reminder to ensure the work is completed by 3 August 2012 - a date that has passed, so for any aircraft that has not complied, the operator must treat the directive as an outstanding mandatory requirement and arrange immediate compliance to regain airworthiness.