AD/B747/346 - Driessen Galleys

An Airworthiness Directive is a legally enforceable notification issued by CASA under the Civil Aviation Act 1988 and Civil Aviation Regulations 1988. It requires aeroplane owners and operators to correct a condition that is considered an unsafe condition that is likely to exist or develop in other aeroplanes of the same type design. AD/B747/346 follows the format of an Australian AD that adopts a corresponding FAA airworthiness directive (FAA AD 2006-12-06, Amendment 39-14631). The underlying problem, as stated in the Background section, is that the FAA has received results from testing and reports from the manufacturer indicating unacceptable flammability properties of wire wrapping installed in certain galleys and closets. The risk is fire propagation or smoke in the cabin area due to electrical arcing or sparking and ignition of the spiral wire wrapping.

The Directive uses two key compliance methods: inspection (or record review) to identify affected part numbers, and replacement of the spiral protective wrapping if the part number matches. The concept of "positive determination" is crucial for the records review alternative. The maintenance records must unambiguously show which galley part number is installed; if the records are incomplete or ambiguous, a physical inspection is required. The Directive also explicitly defines "galley" to include "buffet" and "closet" as used in the referenced service information, ensuring the scope is not misinterpreted.

The credit for previous accomplishment (Table 2) saves operators who already replaced the wrapping under the original service bulletins from repeating the work. However, the credit is limited to replacements done before the Directive's effective date using the exact service bulletins listed. Replacements done after the effective date but using earlier revisions are not automatically credited; they must meet the later Revision 1 requirements or an approved AMOC. The AMOC provision allows the FAA to approve alternative methods, which are then recognised by CASA. This creates a mechanism for flexibility if the approved service information later changes, but it also places a burden on operators to track FAA approvals that may not be automatically reflected in the Australian register.

The primary audience for this Directive is any operator of a Boeing 747-400 or 747-400F series aeroplane registered in Australia or operating under an Australian air operator certificate. It also affects any maintenance organisation that performs work on those aeroplanes, particularly those responsible for galley inspections and electrical cable work. The Directive applies only to aeroplanes equipped with galleys manufactured by Driessen Aircraft Interior Systems or Showa Aircraft Industries that have part numbers listed in the specified service bulletins. Aeroplanes with galleys from other manufacturers are not affected. The Note 1 provision clarifies that the term "galley" includes "buffet" and "closet" where those terms appear in the service information, so aeroplanes with certain closets or buffets that are functionally part of the galley installation are also within scope.

The compliance burden falls on the operator, who must arrange for the inspection or records review and any necessary replacement within the 72-month window. That period is generous for a one-time replacement, but the operator must not forget the requirement if the aeroplane is in service for many years. The cost of the replacement includes the parts (new spiral protective wrapping) and labour. The Directive does not quantify either. The service bulletins may also require additional procedures such as access to the galley, disconnection of electrical cables, and potential removal of other components. There is no provision for cost recovery from the manufacturer or regulator.

Suppliers of the spiral protective wrapping and those who perform the flammability testing benefit from the Directive because it creates mandatory demand for their products. However, those costs are ultimately borne by airlines and, through ticket prices, by passengers. The Directive also affects the parts supply chain: operators may need to source the specific wrapping material approved in the service bulletins, which could be a sole-source item. The AMOC provision allows alternatives if approved by the FAA, but obtaining an AMOC is a process that takes time and may require engineering justification. Small operators with limited engineering resources may find that particularly burdensome.

The central duty is clear: within 72 months of 3 August 2006, the operator must perform the inspection (or records review) and, if an affected galley is found, replace the spiral protective wrapping. The operator also has a duty to ensure that any replacement is done in accordance with the applicable service information, meaning the exact procedures, materials, and tolerances specified in Boeing's documentation. If the operator chooses to rely on the records review alternative, there is a duty to positively determine the part numbers; a mere assertion without documentary evidence is insufficient. The operator bears the burden of proof that the records support positive identification.

The Directive also imposes a duty on the operator to check that any previous replacement (before the effective date) was done with the correct service bulletin revision listed in Table 2. If the replacement used a different revision or a different method, it is not credited. The operator may then need to redo the replacement to the Revision 1 standard.

The rights under the Directive are limited. The operator has the right to use an FAA-approved AMOC for later revisions of the service bulletins, but that is contingent on the FAA granting approval. The operator does not have an automatic right to propose its own alternative method; it must either follow the prescribed method or obtain an AMOC through the FAA. This creates a potential regulatory bottleneck if the FAA is slow to approve a new revision. The Directive itself does not provide a mechanism for Australian operators to seek a direct AMOC from CASA; it only recognises FAA-approved AMOCs for later revisions. For any other deviation, the operator would need to seek a separate variation or exemption under the Civil Aviation Regulations.

The 72-month compliance period gives the operator substantial flexibility in scheduling the work during routine maintenance. However, if the operator fails to complete the work by the deadline, the aeroplane may not be released to service until the Directive is complied with, creating grounding risk. The operator also has the right to rely on the records review rather than inspection, which is a cost-saving measure, but only if the records are adequate. If the records are insufficient, the operator must conduct a physical inspection. This creates an incentive to maintain accurate part-number records.

Failure to comply with an Airworthiness Directive is a serious breach of the Civil Aviation Act 1988 and Civil Aviation Regulations 1988. The specific penalty provisions are not set out in the Directive itself, but under the Act, the maximum penalty for an individual who contravenes a civil aviation requirement can be up to 50 penalty units (currently $13,750) or imprisonment for up to 2 years for certain provisions. For a body corporate, the maximum penalty can be up to five times that amount, or $68,750. These penalties are per offence, and each day the non-compliance continues may be a separate offence. In practice, CASA may also issue a direction to ground the aeroplane or prohibit its operation until the Directive is complied with. Such a direction can be enforced by injunction.

CASA has a range of enforcement tools: infringement notices (on-the-spot fines), enforceable undertakings, suspension or cancellation of an air operator certificate, and prosecution. For an AD like this, the most likely enforcement action is a direction to rectify followed by a possible fine if the operator fails to comply by the deadline. The regulatory consequences extend beyond financial penalties: non-compliance can affect the operator's safety record, insurance premiums, and standing with regulators and customers. It may also trigger mandatory reporting obligations if a violation is discovered.

The Directive itself does not specify any penalty because it is a technical standard, not a penal instrument. However, the operator's obligation to maintain the aeroplane in an airworthy condition includes compliance with all ADs. Under CAO 100.7 or similar, the operator must have a system to track and complete ADs within their compliance times. Failure to do so is a breach of the operator's continuing airworthiness management obligations. For a one-off AD with a long compliance time, the risk is that the operator simply forgets or deprioritises it. The enforcement risk increases as the deadline approaches and the regulator may audit AD compliance as part of surveillance checks.

AD/B747/346 is an Australian airworthiness directive that adopts the requirements of FAA AD 2006-12-06. This makes it part of a broader framework where Australia recognises foreign airworthiness directives to ensure that aeroplanes operating in Australia meet equivalent safety standards. The interaction with the FAA AD is direct: the Australian AD incorporates by reference the U.S. service bulletins and the FAA's AMOC process for later revisions. If the FAA revokes or amends FAA AD 2006-12-06, the Australian AD would likely need to be amended to stay aligned, but until then the Australian AD stands as a separate legal instrument. An operator could face conflicting requirements if the FAA issues a subsequent AD that supersedes or modifies this requirement, but the Australian AD has not been updated.

The Directive also interacts with the Civil Aviation Regulations (CARs), particularly Part 42 (Continuing Airworthiness) and Part 66 (Maintenance). CAR 42.020 (old numbering) or the equivalent under Part 42 of the Civil Aviation Safety Regulations (CASR) requires the operator to ensure that the aeroplane complies with all applicable ADs. The AD must be entered on the operator's maintenance schedule or airworthiness program. The work performed under this AD must be certified by a licensed aircraft maintenance engineer (LAME) or an approved maintenance organisation. The replacement of spiral protective wrapping on galley electrical cables is likely to be considered a maintenance task requiring certification under Part 43 or Part 145, depending on the approval level.

The Directive also interacts with any Australian Standards or regulations governing flammability of materials in aircraft cabins. The AD specifies that the new spiral protective wrapping must have been "shown to meet certain flammability testing requirements". The specific testing is not detailed in the AD but would be found in the referenced Boeing service bulletins, which in turn refer to FAA or industry standards such as FAR Part 25 fire testing. If those standards change, the AD may become outdated, requiring an AMOC or revision. Operators who have already replaced the wrapping using later testing standards may still need to ensure their wrapping meets the standards referenced in the AD as of 2006.

Finally, the AD affects contracts between operators and maintenance providers. A maintenance contract may require the provider to ensure the aeroplane is AD-compliant, shifting liability for oversight. The AD also interacts with insurance policies: non-compliance could void coverage or lead to exclusion for a known unsafe condition. The Directive itself creates no private rights of action but may be used as evidence of a standard of care in litigation following an incident.

The source text of AD/B747/346 (8/2006) does not show any amendments. It appears to be the original issue dated 20 June 2006, effective 3 August 2006. There is no indication that it has been superseded, amended, or withdrawn. Given that this is a one-time AD with a compliance period of 72 months, it would have achieved full compliance or became obsolete by 3 August 2012. For an aeroplane still operating beyond that date, if the work was completed as required, the AD no longer imposes an ongoing obligation. However, if the operator failed to comply, the AD would still be relevant for enforcement action. The AD would also remain on the aeroplane's permanent records as historical compliance evidence.

In the normal course, CASA may have issued a later AD that supercedes this one, perhaps extending the compliance time or modifying the service information. But the source provided contains no such amendment. It is possible that CASA did not review this AD after it was issued because the FAA may have updated the underlying requirements. ADs are often reviewed after a period to verify effectiveness, but the source does not indicate any such review. The implication is that the operator must treat the AD as is, with no later official modifications known from this source.

It is also notable that the AD itself provides for acceptance of later revisions of the Table 1 service bulletins if approved by the FAA as an AMOC. That is not an amendment to the AD but a built-in dynamic reference. The operator must therefore also track FAA approvals of later revisions, which could change the precise steps required for replacement. If the FAA issues Revision 2 of the service bulletin, the operator may be able to use it if FAA approves it as an AMOC to AD 2006-12-06. The Australian AD does not independently approve those later revisions; it merely states they are acceptable for compliance if the FAA approves. This creates a dependency on the FAA's process and requires the operator to monitor U.S. regulatory developments even though the AD is Australian.

The source text does not cite any litigation. Airworthiness directives are rarely litigated on their merits because they are based on technical safety findings and courts typically defer to the regulator's expertise. However, there could be litigation around enforcement actions where an operator challenges the regulator's interpretation of the AD or the reasonableness of the compliance time. For AD/B747/346, the 72-month compliance period is generous, so a challenge based on insufficient time would be unlikely. A challenge based on the cost being disproportionate to the risk might be possible but would face a high bar because safety decisions are discretionary.

There could also be litigation between operators and maintenance providers or sellers of aeroplanes over whether an aeroplane was AD-compliant at the time of sale. For example, if an operator bought a used 747-400 and later discovered the galley wrapping had not been replaced, the operator might sue the seller for breach of contract or misrepresentation. The AD would be central evidence of the required standard. Conversely, if a seller warranted compliance and the AD was not done, the buyer could claim damages.

Another potential area for litigation is product liability against the manufacturer of the galleys (Driessen or Showa) or the spiral wrapping material supplier if a fire occurred due to non-compliant wrapping. But that would involve manufacturing defect claims, not the AD itself. The AD might be used as evidence that the material was known to be defective, supporting a negligence claim.

No reported Australian decisions concerning this specific AD have been identified in the source, and given the age of the AD, any litigation would likely have been long concluded. The absence of litigation history suggests that operators complied without controversy or that any disputes were resolved privately. The AD is a standard technical directive with clear requirements and a long lead time, which reduces the incentive to litigate.

The biggest trap in this AD is the interplay between the two tables. Table 1 lists the service bulletins that define both the identifying part numbers and the replacement procedure. But the previous accomplishment credit in Table 2 allows the use of the original issues of those same bulletins dated 15 March 2001, not the Revision 1 issues. An operator who replaced the wrapping using the original issue after the effective date (i.e., after 3 August 2006) would NOT be credited because Table 2 only credits replacements done before the effective date. Therefore, an operator who performed the replacement in, say, January 2007 using the original 2001 bulletin would still be non-compliant and would need to redo the replacement using Revision 1. The AD does not explicitly state this, but the logic is clear from the wording: "prior to the effective date of this Directive". This is a trap for operators who may have thought any earlier work was good enough.

Another trap is the reliance on the records review alternative only if part numbers can be "positively determined". If the maintenance records show the galley model number but not the specific part number of the spiral protective wrapping, that is insufficient. The operator must confirm that the P/N of the installed galley matches the list. If the records are ambiguous, physical inspection is required. A resource-constrained operator might be tempted to claim records are adequate when they are not, exposing themselves to enforcement risk.

The AD also incorporates by reference complex technical information in the Boeing service bulletins. Those bulletins are not reproduced in the AD. An operator must obtain the correct revision from Boeing, which may be proprietary and require payment. Failure to use the correct revision could render the replacement non-compliant even if the work was done in good faith. The AMOC provision for later revisions is helpful but requires the operator to confirm that the FAA really approved the revision as an AMOC. If the operator uses Revision 2 of the bulletin without verifying its AMOC status, the work may not comply with the Australian AD because the AD only recognises FAA-approved later revisions.

Finally, the 72-month compliance period may seem long, but it can easily be forgotten in the busy maintenance cycle of a large aeroplane. Many operators use a compliance tracking system that flags due dates. If the aeroplane is sold or leased during that period, the incoming operator must check whether the AD was complied with; the outgoing operator may not have transferred records properly. There is no recurring inspection after the initial replacement, so once done, the AD is closed. But if it was never done, the aeroplane is unairworthy.

The compliance path is straightforward but requires methodical execution. Start by identifying the aeroplane model (747-400 or 747-400F) and then determine whether any galleys manufactured by Driessen Aircraft Interior Systems or Showa Aircraft Industries are installed. This can be done by reviewing the aircraft's equipment list or the galley part numbers from the maintenance records. If the aeroplane has no galleys from these manufacturers, no further action is needed. But the operator should document that determination for the record.

If galleys from Driessen or Showa are present, the operator must inspect each galley (or review records) to see if the installed part number matches any part number listed in Boeing Special Attention Service Bulletin 747-25-3264 (Revision 1, 11 November 2004) for the 747-400, or Boeing Service Bulletin 747-25-3275 (Revision 1, 4 April 2004) for the 747-400F. The operator should obtain a copy of the relevant service bulletin and check the P/N list. If the part number is not listed, document that and close the AD.

If the part number is listed, the operator must replace the spiral protective wrapping of the electrical cables of that galley with new wrapping that meets the flammability testing requirements specified in the applicable service bulletin. The replacement must be performed in accordance with all instructions in the bulletin, including any accessory removal, cable handling, and torque requirements. The new wrapping material must be sourced from an approved supplier; its traceability is critical.

Before proceeding, check whether the spiral protective wrapping was already replaced before 3 August 2006 using the original issue of the same bulletin (dated 15 March 2001). If so, and if the records confirm that the original issue was used, the operator can claim credit and no further replacement is needed. If the replacement was done after 3 August 2006 using the original issue, it does not qualify; the operator must redo the replacement using Revision 1.

If the operator wishes to use a later revision of the service bulletin (e.g., Revision 2 or 3), they must first confirm that the FAA has approved that revision as an AMOC to FAA AD 2006-12-06. The operator should obtain evidence of the FAA's approval (e.g., an FAA letter or a reference on the FAA's website) and keep it in the aircraft maintenance records. Without that evidence, the later revision is not acceptable for compliance with the Australian AD.

The work must be certified by an appropriately licensed aircraft maintenance engineer (LAME) or an approved maintenance organisation. The certification must reference this AD number (AD/B747/346) and the specific service bulletin used. The compliance completion should be recorded in the aircraft's continuing airworthiness record system. Given the one-time nature, there is no recurring action, but the operator should ensure the AD is removed from the active compliance schedule once completed.

If the aeroplane is sold or leased after compliance, the new operator should verify that the AD was fully completed and that all records are transferred. The operator should also be aware that if the AD was never completed, the aeroplane is unairworthy and cannot be flown until the work is done. The 72-month compliance period has long expired, so any aeroplane that has not had the work done is currently non-compliant and needs immediate rectification before further flight.