AD/B747/336 Amdt 1 - Nacelle Strut Attach Pin/Bolt, Dual Side Brace, and Underwing Midspar Fitting

This instrument builds on a small set of interlocking regulatory concepts: an Airworthiness Directive requirement, cross-acceptance of an FAA Alternative Method of Compliance documented on a specific FAA form, the applicability tied to a manufacturer service bulletin revision, and a safety rationale based on reported component degradation.

Airworthiness Directive and technical requirement. The directive instructs operators to carry out the "technical requirements of FAA AD 2005-19-09 Amdt 39-14274." The CASA instrument does not repeat the technical inspection or repair steps; it refers operators to the FAA AD for the substantive compliance regimen [Requirement]. Therefore the required inspections and corrective actions are those contained in the FAA AD, not newly drafted material in this CASA amendment.

Cross-acceptance of FAA AMOCs on form 8100-9. The text permits corrective actions already approved on FAA form 8100-9, and approved by the Manager, Seattle ACO or that Manager’s delegate as an AMOC to the FAA AD, to be carried out "without the need to obtain an exclusion from CASA from this airworthiness directive" [Requirement]. The concept is a procedure for recognising FAA approvals as sufficient evidence of an acceptable alternative means of compliance for the specific repairs and repeat inspections documented on that form.

Applicability tied to service bulletin revision. The directive’s applicability is not by model name alone; it is qualified by reference to a Boeing Service Bulletin , 747-54A2218 Revision 1 dated 24 February 2005 , or later FAA-approved revision. That means individual aircraft must be identified in the service bulletin revision to be within the AD’s scope [Applicability].

Safety trigger and scope of actions. The named failure modes are specific mechanical degradations: corroded, migrated, and rotated bearings for dual side braces in the engine mounting struts; a fractured retainer for an eccentric bushing on a dual side brace side link; and wear and damage to the underwing midspar fitting on an outboard strut. The stated safety outcome to be avoided is loss of a load path for the dual side brace or underwing midspar fitting, with consequent load redistribution potentially leading to strut and engine separation during flight [Background].

Delegation and administrative effect. The instrument is signed by a CASA delegate and dated 11 December 2008. The amendment explicitly reduces administrative friction by removing the requirement for operators to "continually apply for an exclusion" from CASA when the corrective action has already been approved on FAA form 8100-9 by the Seattle ACO Manager or delegate [Background; signature section]. The core concept is administrative recognition of specific FAA approvals to streamline maintenance administration for affected operators.

The directive affects owners and operators of Boeing 747 series aircraft identified in Boeing Service Bulletin 747-54A2218 Revision 1 (24 February 2005) or later FAA-approved revision. The models listed explicitly are: 747-100, -100B, -100B SUD, -200B, -200C, -200F, -300, -400, -400D, -400F, 747SR, and 747SP series aircraft [Applicability]. Only aircraft identified in the referenced service bulletin revision fall within the scope; the document makes that cross-reference the determinative identification mechanism.

Maintenance organisations and repair stations performing inspections or corrective work on those aircraft are likely affected because the directive prescribes the technical requirements of FAA AD 2005-19-09 and allows use of FAA-approved AMOCs documented on FAA form 8100-9 approved by the Manager, Seattle ACO or delegate [Requirement]. Organisations responsible for preparing or submitting AMOCs will be directly interested in whether their AMOC has been documented on form 8100-9 and approved by the Seattle ACO Manager or delegate, because only such AMOCs are explicitly permitted to be used without a CASA exclusion.

Personnel who sign for airworthiness and continuing airworthiness compliance (accountable managers, maintenance certifying staff) will need to confirm that the inspections, repairs, or repeat inspections they authorise are either in strict accordance with FAA AD 2005-19-09 or have an FAA form 8100-9 AMOC signed off by the appropriate FAA authority. CASA’s amendment changes the paperwork flow for those personnel by removing the need to seek a CASA exclusion where the FAA form 8100-9 AMOC exists and is approved by the referenced FAA authority [Requirement; Background].

CASA as regulator and its delegates are parties to the instrument. The amendment is signed by a CASA delegate, indicating administrative delegation in the issuance of airworthiness directives. The FAA Seattle ACO Manager (or their delegate) is given an operational role in approving AMOCs that CASA will accept without further exclusion requests [Requirement].

Lastly, other national aviation authorities or lessors may be indirectly affected because the directive ties compliance to FAA documentation and approvals. Operators registered in Australia must follow the CASA directive; operators registered elsewhere but operating the same aircraft models will need to follow their national authority’s instrument, but the CASA amendment shows a pathway by which CASA recognises specified FAA approvals for Australian-registered operators.

Duties imposed by the instrument are narrow and clearly referenced. The primary duty is to comply with the technical requirements of FAA AD 2005-19-09 Amdt 39-14274: operators of applicable aircraft must carry out the inspection and corrective action regimen specified in that FAA AD. The CASA text states this as a mandatory Requirement: "Action in accordance with the technical requirements of FAA AD 2005-19-09 Amdt 39-14274" [Requirement].

A further duty, implicit but present, is to establish whether a specific aircraft falls within the AD’s applicability by reference to Boeing Service Bulletin 747-54A2218 Revision 1, dated 24 February 2005, or to a later FAA-approved revision. Compliance obligations attach only to aircraft identified in that service bulletin revision [Applicability].

Operators also have a duty to ensure that any corrective actions they carry out under the alternative pathway are approved on FAA form 8100-9 and have been approved by the Manager, Seattle ACO or that Manager’s delegate as an AMOC to FAA AD 2005-19-09. Only then does the CASA amendment relieve them from having to obtain a separate exclusion from CASA [Requirement]. The duty therefore includes maintaining documentary proof of FAA form 8100-9 AMOC approval by the specified FAA authority.

Rights conferred. The instrument creates a procedural right for operators to execute FAA-approved AMOCs without repeatedly applying for exclusions from CASA. The text states that such FAA-approved AMOCs "may be carried out without the need to obtain an exclusion from CASA from this airworthiness directive" [Requirement; Background]. That is a right to implement a specific set of FAA-approved repairs and repeat inspections with CASA acceptance, provided the approval is properly documented and issued by the named FAA authority.

Limits on rights. The CASA instrument does not provide an open-ended right to use any FAA approval. The scope is confined to corrective actions that are both (1) recorded on FAA form 8100-9 and (2) approved by the Manager, Seattle ACO or delegate as an AMOC to FAA AD 2005-19-09. The instrument gives no indication that other FAA approvals, other AMOCs not on form 8100-9, or approvals by other FAA offices will be acceptable without an exclusion. Operators must ensure the specific documentary and approval chain is present.

Administrative obligations. The directive changes the administrative interaction between operators and CASA: rather than continuously applying for an exclusion from the CASA AD for FAA-approved AMOC repairs or inspections, operators now may rely on the FAA form 8100-9 AMOC properly approved by the Seattle ACO Manager or delegate. That shifts some administrative burden away from CASA interactions and places the onus on operators to secure the FAA form 8100-9 AMOC and to retain it as evidence of compliance [Background; Requirement].

Unspecified duties. The instrument does not set out monitoring, reporting, or record-retention periods, nor does it provide specific instructions on how operators should evidence or present the FAA form 8100-9 approval to CASA. Those operational details must be inferred to reside in the implementing guidance or the FAA AD itself. The CASA text simply references the FAA AD and the AMOC form as the determinative documents [Requirement; Compliance].

The source text states the requirement to act in accordance with FAA AD 2005-19-09 and sets an effective date for the amendment, but it does not contain an express section specifying penalties, sanctioning parties, or enforcement procedures. The document identifies the directive as an airworthiness directive and sets compliance as "As specified in the Requirement document" [Compliance]. That means the substantive enforcement mechanisms, timeframes for inspections and corrective actions, and any consequences for non-compliance are those defined in the FAA AD or in general aviation safety legislation and CASA enforcement practice rather than spelled out in this short amendment text.

Because the CASA instrument refers operators to FAA AD 2005-19-09 for the technical requirements, enforcement of the technical steps would, in practice, be through the mechanisms that CASA normally uses to enforce compliance with airworthiness directives and continuing airworthiness obligations. The instrument itself does not add new procedural enforcement provisions or civil penalty schedules; it instead modifies administrative treatment of FAA form 8100-9 AMOCs so that operators need not apply for exclusions where the AMOC is properly approved [Requirement; Background].

The effective date is given: the amendment "becomes effective on 12 February 2009" and the original AD became effective 24 November 2005. The presence of effective dates indicates the point at which the procedural change and the substantive AD obligations must be met or become operationally relevant to operators [Compliance; This Amendment becomes effective on 12 February 2009; The original issue ... 24 November 2005].

Absent explicit penalty language, a practitioner should look to: (1) FAA AD 2005-19-09 for prescribed compliance intervals and corrective action requirements; (2) CASA's overarching regulatory powers and enforcement instruments for sanctions applicable to failure to comply with CASA airworthiness directives; and (3) the usual regulatory requirement for operators to maintain airworthiness records demonstrating compliance. None of those regimes are spelled out in this amendment text, so the amendment should be read in conjunction with CASA’s enforcement policy and the full text of the FAA AD to determine specific enforcement exposures.

The amendment is explicitly cross-referential and designed to interact with US Federal Aviation Administration material. It requires actions "in accordance with the technical requirements of FAA AD 2005-19-09 Amdt 39-14274" [Requirement]. Accordingly, the substantive inspection and repair regimen is sourced to US FAA regulatory material rather than re-stated in the CASA text. Operators must therefore consult and comply with the FAA AD as part of their obligations under the CASA instrument.

The amendment creates an acceptance channel for FAA Alternative Methods of Compliance. It authorises corrective actions approved on FAA form 8100-9 and approved by the Manager, Seattle ACO or delegate as an AMOC to the FAA AD to be implemented without obtaining CASA exclusions [Requirement]. That is a form of cross-jurisdictional administrative recognition whereby CASA accepts a particular FAA approval mechanism (form 8100-9 with Seattle ACO endorsement) as sufficient for Australian compliance in this specific context.

The applicability is linked to a Boeing service bulletin and its FAA-approved revisions: "as identified in Boeing Service Bulletin 747-54A2218 Revision 1, dated 24 February 2005, or later FAA approved revision" [Applicability]. That introduces a contract/manufacturer-document interaction: whether an aircraft is subject to the CASA AD depends on whether it is identified in that service bulletin revision. Service bulletins are manufacturer documents; their role here is to identify affected serial numbers or configurations that fall within the AD’s scope.

Where Australian-registered operators are using FAA AMOCs, they must ensure the AMOC is documented on the particular FAA form 8100-9 and has the required Seattle ACO Manager (or delegate) approval. Other FAA approvals that do not meet those documentary or approving-office criteria are not covered by this CASA amendment. In other words, the CASA instrument imports certain FAA approvals but only via a narrowly defined administrative channel.

The instrument does not expressly reference any Australian Acts, regulations, or CASA enforcement policies by citation. It does not alter any statutory obligations under Australian aviation law; rather, it affects the administrative interface between CASA and operators by recognising specified FAA AMOCs. Practitioners should therefore view this instrument as a targeted administrative concession concerning AMOC handling, not as a displacement of domestic airworthiness regulation. The underlying statutory powers permitting CASA to issue and enforce airworthiness directives remain the framework within which this amendment operates, but those statutory references do not appear on the face of this short amendment text.

The amendment is described on the face of the document as "AD/B747/336 Amdt 1." The instrument notes that the original issue of this Airworthiness Directive became effective on 24 November 2005, and that this Amendment becomes effective on 12 February 2009. The amendment is dated and signed on 11 December 2008 by a CASA delegate, David Punshon [This Amendment becomes effective on 12 February 2009; The original issue ... 24 November 2005; signature section].

The substance of the amendment is specifically to permit the use of FAA-approved AMOCs documented on FAA form 8100-9 and approved by the Manager, Seattle ACO or delegate to be carried out without operators needing to obtain an exclusion from CASA for each such repair or repeat inspection. The amendment is therefore an administrative change to the original CASA AD, rather than a substantive re-write of the technical inspections and repairs. The technical requirements remain those of the referenced FAA AD, while the amendment alters CASA’s prior handling of FAA AMOCs in relation to this AD [Requirement; Background].

The administrative history visible in the text indicates the following sequence: FAA reported component issues and issued FAA AD 2005-19-09; CASA originally issued an AD that became effective 24 November 2005; CASA later issued this amendment (Amdt 1) to address the administrative burden of operators needing exclusions by accepting certain FAA AMOCs without exclusion; the amendment was signed on 11 December 2008 and made effective 12 February 2009. Those dates and the signatory are the explicit amendment history provided in the document.

The amendment also references Boeing Service Bulletin 747-54A2218 Revision 1 dated 24 February 2005, or later FAA-approved revision, as the determinative identification mechanism for affected aircraft. Any later FAA-approved revision of that service bulletin would therefore change which aircraft fall within the AD’s scope, meaning the amendment anticipates the manufacturer's service bulletin revision process and ties CASA coverage to FAA-approved revisions of the bulletin [Applicability].

No other amendments, revocations, or supersessions are recorded in the text. The document therefore should be read in conjunction with the original AD and any subsequent CASA instruments that may have altered the regulatory landscape after the effective date. The text itself provides only the single amendment history line and the effective dates cited.

The instrument contains no reference to litigation, appeals, or judicial review. The document does not name any legal proceedings, nor does it cite any court decisions or cases. The text is administrative and addresses technical compliance and an administrative concession concerning AMOCs; it is silent on any disputes, challenges, or litigation arising from the AD or the amendment.

Given the absence of litigation references in the source, there is no source-grounded litigation history to report. Practitioners seeking litigation context should consult external case law databases and CASA or court archives for any administrative appeals, judicial review proceedings, or enforcement actions that post-date this instrument, because the printed amendment itself contains no litigation record.

Narrow scope of AMOC acceptance. The CASA amendment permits use of FAA AMOCs only where the AMOC is documented on FAA form 8100-9 and where that AMOC has been approved by the Manager, Seattle ACO or that Manager’s delegate as an AMOC to FAA AD 2005-19-09. The instrument does not say that other FAA approvals, other documentation formats, or approvals by other FAA offices will be acceptable without a CASA exclusion [Requirement]. Operators must therefore verify the precise paperwork and approving office before relying on the amendment.

Applicability is by service bulletin identification, not model name alone. The AD applies to specific Boeing 747 models "as identified in Boeing Service Bulletin 747-54A2218 Revision 1, dated 24 February 2005, or later FAA approved revision" [Applicability]. Aircraft owners should not assume every airframe of a listed model is affected; they must check whether the particular aircraft is identified in the referenced service bulletin revision.

Reliance on the FAA AD for technical details. The CASA amendment does not restate the technical inspection intervals, thresholds, or repair instructions from FAA AD 2005-19-09. It directs operators to "act in accordance with the technical requirements of FAA AD 2005-19-09" [Requirement]. Operators unfamiliar with that FAA AD may miss critical timing or technical steps if they rely solely on the CASA text.

No penalty or enforcement detail in the instrument. The amendment does not set out enforcement measures or penalties; compliance is "as specified in the Requirement document" and enforcement will be via CASA’s general powers and the FAA AD provisions as applicable. Operators seeking clarity on enforcement consequences must consult CASA enforcement policies and the FAA AD's compliance schedule [Compliance].

AMOC documentation retention and proof. The instrument allows FAA form 8100-9 AMOCs to be used without CASA exclusions, but it does not specify how operators should document, present, or retain those approvals to demonstrate compliance to CASA inspectors. Operators should therefore maintain clear records of the FAA form 8100-9 approval with the Seattle ACO Manager or delegate signature to avoid disputes during oversight.

Potential mismatch of authority or timing. The amendment accepts AMOCs approved by the Seattle ACO Manager or delegate. If an operator has an AMOC approved by a different FAA office, or if an AMOC is in draft or awaiting FAA signature, the CASA amendment will not automatically validate it. Operators must ensure the approval is final and by the specified FAA authority.

No change to substantive safety requirements. This amendment is administrative in nature; it does not reduce or relax the technical inspection and repair requirements set out in FAA AD 2005-19-09. The amendment changes administrative procedure, not the technical standard. Operators should not interpret the amendment as reducing the technical safety obligations contained in the FAA AD.

Follow the FAA AD technical requirements. The primary compliance step is to perform the inspections and corrective actions exactly as required by FAA AD 2005-19-09 Amdt 39-14274. The CASA amendment places the technical regimen in the FAA AD; operators must obtain, read, and implement that FAA AD for the precise inspection methods, intervals, and repair procedures [Requirement].

Confirm applicability using Boeing Service Bulletin 747-54A2218 Revision 1 or later FAA-approved revisions. Determine whether the specific aircraft is listed in the referenced service bulletin revision; if it is not identified there, the CASA AD will not apply to that airframe under this instrument [Applicability]. Use the later FAA-approved revision if applicable.

If using an Alternative Method of Compliance, secure the FAA form 8100-9 AMOC. Ensure the AMOC corrective action (repair or repeat inspection) is recorded on FAA form 8100-9 and has been approved by the Manager, Seattle Aircraft Certification Office or that Manager’s delegate as an AMOC to FAA AD 2005-19-09. Only such form 8100-9 approvals are explicitly accepted by CASA without the need for a CASA exclusion [Requirement].

Retain documentary proof. Keep a copy of the signed FAA form 8100-9 and any supporting FAA documentation showing the Seattle ACO Manager or delegate approval. Maintain the documentation as part of the aircraft’s maintenance records to demonstrate to CASA inspectors or auditors that the repair or repeat inspection was performed under an FAA-approved AMOC that CASA accepts under this amendment [Requirement; Background].

Adhere to the effective date. The amendment becomes effective on 12 February 2009. Ensure any reliance on the procedural concession in the amendment (carrying out FAA form 8100-9 AMOCs without CASA exclusions) aligns with that date and with any transitional requirements that may be contained in the FAA AD or in CASA guidance [This Amendment becomes effective on 12 February 2009; Compliance].

Coordinate with maintenance certifying staff and the accountable manager. Ensure that those who sign for work understand that the CASA AD requires compliance with the FAA AD and that only FAA form 8100-9 AMOCs approved by the Seattle ACO Manager or delegate qualify for the exclusion-from-exclusion treatment. Communicate to maintenance providers that they must deliver the FAA form 8100-9 documentation to the operator for retention.

If in doubt, seek clarification. The instrument removes the need to apply for CASA exclusions where the exact FAA form 8100-9 AMOC with Seattle ACO endorsement exists, but it does not specify how to present or log such approvals. Operators uncertain about the sufficiency of their paperwork or the identity of the approving FAA office should seek clarification from CASA or the Seattle ACO Manager to avoid regulatory gaps.

Do not assume other FAA approvals suffice. If a proposed AMOC is approved in another format, by another FAA office, or is pending approval, do not implement it assuming CASA acceptance under this amendment. Obtain the form 8100-9 with the required Seattle ACO Manager or delegate approval or proceed under a CASA exclusion if appropriate.

Monitor for service bulletin and FAA AD revisions. The applicability is tied to a specific service bulletin revision and the technical requirements to an FAA AD. If Boeing issues a later service bulletin revision that is FAA-approved, or if the FAA revises AD 2005-19-09, operators must update their compliance plans accordingly. The CASA amendment explicitly allows "later FAA approved revision" of the service bulletin as determinative [Applicability].