AD/B767/204 - Forward Cargo Compartment Wire Bundles

The central concept is the detailed inspection, which the directive defines in Note 1 as an intensive visual examination of a specific structural area, system, installation, or assembly to detect damage, failure, or irregularity. The definition specifies that available lighting is normally supplemented with a direct source of good lighting at an intensity deemed appropriate by the inspector. Inspection aids such as mirrors and magnifying lenses may be used. Surface cleaning and elaborate access procedures may be required. This definition is important because it sets the expected standard of scrutiny: this is not a casual walk-around but a methodical, well-lit search requiring access to typically hidden areas. The directive targets discrepancies, a term it defines to include chafing or damage of wire bundles near the stand-offs that attach the cargo ceiling liner to the floor beams. The concept of clearance is central to the corrective action requirements. The directive establishes three different clearance thresholds for wire bundles generally and two thresholds for power feeder cables specifically. For ordinary wire bundles relative to cargo liner standoffs, the thresholds are 6.35 mm (0.25 in) and 3.3 mm (0.13 in). Clearance of 6.35 mm or more requires no further action; clearance between 3.3 mm and 6.35 mm requires sleeving and lacing tape; clearance less than 3.3 mm requires sleeving, lacing tape, cable spacers, and straps. For power feeder cables the threshold is 3.3 mm: clearance of 3.3 mm or more requires no further action; less than 3.3 mm requires sleeving, lacing tape, and straps. The power feeder cables W208 and W236 are specifically identified for mandatory inclusion in the inspection. The directive does not define what these cables supply, but the background statement identifies the fuel quantity indication system (FQIS) wires as a particular concern. The safety logic is that damage to FQIS wires could cause arcing between those wires and power wires in the damaged wire bundle, which could transmit electrical energy into the fuel tank and create an ignition source. The concept of grandfathering is also important: work done before the effective date in accordance with earlier revisions of the Boeing service bulletin (original May 2000, Revision 1 December 2001, or Revision 2 May 2002) counts toward compliance, but only if that work covered all wire bundles including W208 and W236 in the specified area. This grandfathering reduces the burden for operators who acted early, but imposes a traceability obligation: the operator must be able to demonstrate that the earlier work covered the correct scope. Finally, the directive introduces an alternative parts concept: a tie cord P/N BMS 13-54 or equivalent may substitute for a tie strap P/N BACS38K2. This is a small but practically significant flexibility for maintenance organisations.

This directive directly affects any person or organisation operating Boeing 767-200 or -300 series aeroplanes on the Australian civil aircraft register. It also affects foreign operators of such aircraft operating within Australian territory under CASA oversight, because airworthiness directives issued by CASA apply to all aircraft operating in Australian territory regardless of registration, subject to any bilateral agreements. The primary compliance burden falls on aircraft operators (the person or company responsible for the continuing airworthiness of the aircraft under Civil Aviation Safety Regulation Part 42 or equivalent). The operator must schedule the inspection within the compliance window, provide access for the inspection, arrange for any required rectification, and maintain records. The directive also affects maintenance organisations (certified under CASR Part 145 or equivalent) that will perform the detailed inspection and any corrective actions. These organisations must have access to Boeing ASB 767-24A0128 Revision 3, must have personnel qualified to perform the detailed inspection as defined, and must have the parts (sleeving, lacing tape, cable spacers, straps, tie cords or tie straps) available. The directive affects certifying engineers and maintenance technicians who must understand the clearance thresholds and apply the correct corrective action for each measurement. The directive affects Boeing as the design approval holder whose service bulletin is incorporated by reference. It affects lessors and financiers who hold security interests in affected aircraft, because compliance with airworthiness directives is typically a condition of lease agreements and affects the residual value of the aircraft. Non-compliance could trigger lease defaults or affect insurance coverage. The directive indirectly affects cargo operators and passengers who may experience schedule disruptions if the inspection uncovers discrepancies requiring rectification before further flight. The directive affects CASA itself as the enforcement authority: CASA must manage the directive, respond to requests for alternative means of compliance, and take enforcement action against non-compliant operators. The directive also affects manufacturers of replacement parts if the directive creates demand for tie cords BMS 13-54 or equivalents. The burden of this directive falls most heavily on operators with large fleets of 767-200 and -300 aircraft, because the cost of inspection and potential rectification scales linearly with fleet size. The directive does not affect operators of 767-400 series or other variants not listed in the applicability.

The primary duty is the duty to inspect: the operator must carry out a one-time detailed inspection of all wire bundles, including power feeder cables W208 and W236, in the forward cargo compartment ceiling area from stations 368 through 742 and right buttock lines 40 through 70. This inspection must follow the Accomplishment Instructions of Boeing ASB 767-24A0128 Revision 3. The inspection is due within 18 months or 6,000 hours time in service after the effective date of 17 February 2005, whichever occurs later. The operator has a duty to repair any discrepancy found during the inspection before further flight. The operator has a duty to examine clearance between all wire bundles (including power feeder cables) and the cargo liner standoffs, concurrently with the inspection. The operator has a duty to apply corrective actions based on the clearance measurements, as specified in the table in the directive. For wire bundles generally, the corrective action depends on whether clearance is 6.35 mm or more (no action), between 3.3 mm and 6.35 mm (install sleeving and lacing tape), or less than 3.3 mm (install sleeving, lacing tape, cable spacers, and straps). For power feeder cables, the thresholds are 3.3 mm or more (no action) or less than 3.3 mm (install sleeving, lacing tape, and straps). The operator has the right to use alternative parts: a tie cord P/N BMS 13-54 or equivalent may be used instead of a tie strap P/N BACS38K2. This is a minor but genuine flexibility that recognises alternative materials may be more available or cost-effective. The operator has the right to rely on prior compliance: inspections and corrective actions performed before the effective date in accordance with Boeing ASB 767-24A0128 original (May 2000), Revision 1 (December 2001), or Revision 2 (May 2002) are accepted, provided they covered all wire bundles including W208 and W236 in the specified area. This grandfathering right carries an implicit burden: the operator must be able to demonstrate that the earlier work covered the correct scope. The operator has the right to request an alternative means of compliance from CASA, although this right is not explicitly mentioned in the directive itself (it arises under the Civil Aviation Safety Regulations generally). The operator also has the right to perform the work using the directive itself as the legal authority, rather than needing separate approval for the maintenance action, because an airworthiness directive under CASR constitutes mandatory continuing airworthiness information. The operator has a duty to maintain records of compliance, including records of the inspection, clearance measurements, any discrepancies found, and corrective actions taken. These records must be retained for the life of the aircraft or as otherwise required by regulation.

Non-compliance with an airworthiness directive is a serious matter under Australian aviation law. The directive itself does not state penalties, but the underlying legal framework provides them. Under the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations 1998 (CASR), operating an aircraft that does not comply with an applicable airworthiness directive is an offence. The operator commits that offence each time the aircraft is flown while non-compliant. Under the Act, penalties can include substantial fines. For a corporation, fines can run to hundreds of thousands of dollars per offence. For an individual, fines can be significant and imprisonment is theoretically possible for the most serious offences involving deliberate disregard for safety. In practice, CASA has a range of enforcement tools short of prosecution. CASA can issue a direction under the Act requiring the operator to ground the aircraft until compliance is achieved. Failure to comply with a direction is itself an offence. CASA can suspend or cancel the aircraft's certificate of airworthiness, which effectively grounds the aircraft until the non-compliance is rectified and the certificate is reinstated. This can have severe commercial consequences for the operator beyond the fine itself. CASA can also issue a remedial order requiring specific action by a specified date. For maintenance organisations, non-compliance with an airworthiness directive can result in suspension or cancellation of the organisation's CASR Part 145 certification, which would prevent the organisation from issuing certificates of release to service. For certifying engineers, non-compliance can result in suspension or cancellation of their authorisations. The directive's incorporation by reference of Boeing ASB 767-24A0128 Revision 3 means that failure to follow the Accomplishment Instructions exactly is failure to comply with the directive. This imposes a strict liability standard: the operator does not need to intend to violate the directive to be in breach. The commercial incentives for compliance are strong: non-compliance voids the airworthiness of the aircraft, which may void insurance coverage and breach leasing agreements. A prudent operator will treat the compliance deadline as a hard cut-off and will not fly the aircraft past that deadline without compliance. The fact that the directive gives a relatively long compliance window (18 months or 6,000 hours, whichever later) suggests CASA regarded the risk as genuine but not imminent, and intended to give operators time to plan the work into scheduled maintenance intervals.

This directive interacts with multiple layers of law and regulation. At the top level, it is issued under the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations 1998, specifically the provisions dealing with airworthiness directives. The directive itself notes in Note 2 that FAA AD 2004-22-25 Amendment 39-13853 refers. This indicates the directive is harmonised with a corresponding U.S. Federal Aviation Administration airworthiness directive on the same subject. For operators of U.S.-registered aircraft operating in Australia, compliance with the FAA AD will likely satisfy compliance with this CASA AD, provided the FAA AD has equivalent scope and compliance requirements. Operators of Australian-registered aircraft, however, must comply with the CASA directive regardless of whether they also comply with the FAA AD. The directive interacts with CASR Part 21 (certification of aircraft and parts) and Part 42 (continuing airworthiness). Under Part 42, the operator is responsible for ensuring that all applicable airworthiness directives are complied with and that records of compliance are maintained. The directive interacts with CASR Part 145 (maintenance organisations) because the inspection and corrective actions constitute maintenance that must be performed by an appropriately authorised organisation or person. The directive interacts with the regulations on maintenance records: compliance with the directive must be recorded in the aircraft's maintenance documentation, typically in the aircraft logbook or continuing airworthiness record system. The directive interacts with the regulations on service bulletins: Boeing ASB 767-24A0128 Revision 3 is incorporated by reference, meaning it has legal force as part of the directive. This is a common technique in aviation regulation but means the operator must obtain the correct revision of the service bulletin; using the wrong revision is not compliance. The directive interacts with international agreements on aviation safety. Australia is a member of the International Civil Aviation Organization (ICAO) and has bilateral airworthiness agreements with other states. Compliance with CASA airworthiness directives is a condition of the aircraft's certificate of airworthiness, which is recognised by other states under these agreements. The directive interacts with commercial law through leasing agreements and insurance policies. Most aircraft leases require the lessee to comply with all applicable airworthiness directives. Non-compliance can constitute an event of default under the lease, giving the lessor the right to repossess the aircraft. Similarly, aviation insurance policies typically exclude cover for loss or damage caused by non-compliance with airworthiness directives. The directive interacts with the criminal law: deliberately falsifying compliance records could constitute fraud or forgery under state or Commonwealth law.

This directive is designated AD/B767/204 and numbered 2/2005. It was issued by James Coyne as Delegate of the Civil Aviation Safety Authority on 13 December 2004. It was notified in the Commonwealth of Australia Gazette on 26 January 2005. It becomes effective on 17 February 2005. The directive supersedes no earlier directive explicitly, but it incorporates and supersedes the inspection requirements of earlier revisions of Boeing ASB 767-24A0128. The service bulletin has its own revision history: a version dated 11 May 2000 (original), Revision 1 dated 6 December 2001, Revision 2 dated 23 May 2002, and Revision 3 dated 24 June 2004. The directive requires compliance with Revision 3. The directive grandfathers work done under the original and Revisions 1 and 2, provided that work covered all wire bundles including W208 and W236 in the specified area. This grandfathering provision means that operators who conducted the inspection under an earlier revision do not necessarily need to repeat it under Revision 3, but they must verify that the earlier work covered the correct scope. The directive amends nothing in the sense that it does not amend any other airworthiness directive. It is a standalone directive. The directive references FAA AD 2004-22-25 Amendment 39-13853, which is the corresponding U.S. FAA directive. The FAA AD likely has its own effective date and compliance timeline; operators with aircraft on both registers must navigate both requirements. The directive does not contain any expiry or sunset clause. It remains in force indefinitely unless it is later superseded by another directive. The directive could be superseded by a later revision of the Boeing service bulletin if CASA issues a new AD referencing that later revision. The directive could also be amended by CASA if service experience reveals that the corrective actions are insufficient or if the compliance timeline needs adjustment. The directive is part of a series of CASA airworthiness directives for the Boeing 767 (designated AD/B767 with sequential numbers). It is number 204 in that series. The directive is part of the broader scheme of CASA ADs for all aircraft types, which are maintained and updated as safety issues arise.

The source text does not record any litigation concerning this directive. Airworthiness directives are rarely the subject of direct litigation in Australia. The legislative framework (the Civil Aviation Act and CASR) gives CASA broad powers to issue directives in the interests of safety, and the courts typically accord significant deference to CASA's technical decisions. A person or operator aggrieved by a directive could seek judicial review under the Administrative Decisions (Judicial Review) Act 1977 or under the common law, but the grounds are limited. To succeed, the applicant would need to show that CASA acted beyond its powers, took into account an irrelevant consideration, failed to take into account a relevant consideration, or made a decision that was so unreasonable that no reasonable decision-maker could have made it. Challenging the technical judgment underlying an airworthiness directive would be extremely difficult because the decision involves specialised engineering knowledge that courts are reluctant to second-guess. The applicant would need expert evidence to show that the directive is not supported by the available evidence or that it imposes requirements that are disproportionate to the risk. No reported Australian case has successfully challenged a CASA airworthiness directive on its merits. More common than direct challenge is the pursuit of an alternative means of compliance (AMOC). An operator who believes the directive's requirements are inappropriate for their specific aircraft can apply to CASA for an AMOC. This is a regulatory process rather than a litigation process. If CASA refuses an AMOC, the operator could seek review of that refusal, but again the prospects are limited. The directive's grandfathering provision reduces the incentive for litigation by giving credit for prior work. The directive's incorporation of FAA AD 2004-22-25 means that any U.S. litigation about that FAA AD could indirectly affect the interpretation of this CASA directive, but Australian courts are not bound by U.S. decisions. The directive is not the subject of any noted enforcement litigation either, meaning CASA has not taken a reported prosecution for non-compliance with this specific directive. This does not rule out that CASA has taken enforcement action that was not publicly reported or not reported as litigation.

The biggest trap is the compliance trigger phrase "whichever occurs later" for Requirement 1. Most airworthiness directives use "whichever occurs first" (e.g., within 18 months or 6,000 hours, whichever occurs first). This directive uses the opposite: within 18 months or 6,000 hours time in service after the effective date, whichever occurs later. This means an operator with an aircraft that accumulates flight hours slowly could fly for well over 18 months before the inspection is due, as long as the hours threshold is not reached earlier. An operator who assumes the usual "whichever occurs first" formula could waste resources by inspecting too early, but more importantly, an operator transitioning from an earlier AD that used "whichever occurs first" might miscalculate the deadline. A second trap is the scope of the grandfathering provision. Work performed earlier under the original or Revision 1 or 2 of the Boeing ASB is acceptable only if it was done on all wire bundles, including power feeder cables W208 and W236, in the specified area. If an operator did the inspection under an earlier revision but only on a subset of wire bundles, or if the records do not confirm the scope, the operator cannot rely on the grandfathering and must repeat the work under Revision 3. A third trap is the distinct clearance thresholds for wire bundles generally versus power feeder cables. For wire bundles, no action is required at 6.35 mm or more, but for power feeder cables, no action is required at 3.3 mm or more. An operator who applies the 6.35 mm threshold to power feeder cables will incorrectly conclude that no action is needed at 3.5 mm, when in fact the directive requires corrective action at that clearance for power feeder cables. A fourth trap is the corrective action escalation for wire bundles at the tightest clearance: sleeving, lacing tape, cable spacers, and straps. This is four separate actions. An operator who installs only sleeving and lacing tape (the corrective action for the intermediate clearance) at a clearance below 3.3 mm has not complied. A fifth trap is the alternative part: the directive says a tie cord P/N BMS 13-54 or equivalent may be used instead of a tie strap P/N BACS38K2. This is permissive, not mandatory. An operator who uses tie cord where the ASB specifies tie straps must ensure equivalence. A sixth trap is that the directive requires the inspection to be done according to the Accomplishment Instructions of the ASB, not simply according to the ASB's general intent. Failure to follow the precise steps of the Accomplishment Instructions is non-compliance. A seventh trap is the definition of detailed inspection in Note 1. It requires supplementary lighting and permits inspection aids. An operator who uses no supplementary lighting or who performs the inspection without adequate access has not conducted a detailed inspection within the meaning of the directive.

Compliance begins with obtaining a copy of Boeing Alert Service Bulletin 767-24A0128 Revision 3, dated 24 June 2004. This document is incorporated by reference and must be used for the inspection, clearance examination, and corrective actions. The operator must schedule the inspection to occur within 18 months or 6,000 hours time in service after 17 February 2005, whichever occurs later. The operator should track both calendar time and flight hours for each affected aircraft. The operator must ensure that the maintenance organisation performing the work has personnel qualified to conduct a detailed inspection as defined in Note 1. The inspection must cover all wire bundles, including power feeder cables W208 and W236, in the forward cargo compartment from stations 368 through 742 and from right buttock lines 40 through 70, routed along the ceiling. The inspection must detect chafing, damage, or any other discrepancies near the stand-offs that attach the cargo ceiling liner to the floor beams. Any discrepancies found must be repaired before further flight, in accordance with the Accomplishment Instructions of the ASB. Concurrently with the inspection, the operator must examine the clearance between all wire bundles (including power feeder cables) and the cargo liner standoffs. The clearance must be measured. Based on the measurements, the operator must apply the correct corrective actions from the table in the directive. For wire bundles: if clearance is 6.35 mm or more, no further action; between 3.3 mm and 6.35 mm, install sleeving and lacing tape; less than 3.3 mm, install sleeving, lacing tape, cable spacers, and straps. For power feeder cables: if clearance is 3.3 mm or more, no further action; less than 3.3 mm, install sleeving, lacing tape, and straps. The corrective actions must be accomplished before further flight after the clearance examination. The operator may use a tie cord P/N BMS 13-54 or equivalent instead of a tie strap P/N BACS38K2. The operator must record all actions in the aircraft continuing airworthiness records: date of inspection, clearance measurements, any discrepancies found and repairs made, corrective actions applied, and the revision of the ASB used. If the operator relies on the grandfathering provision for work done before the effective date, the operator must verify and document that the earlier work covered all wire bundles including W208 and W236 in the specified area, and that it was done in accordance with the original or Revision 1 or 2 of the ASB. The operator should retain these records for the life of the aircraft. If the operator cannot comply with any part of the directive, the operator should apply to CASA for an alternative means of compliance before the compliance deadline. Operating the aircraft after the compliance deadline without compliance or an approved AMOC is an offence. The operator should also check whether the FAA AD 2004-22-25 imposes any additional or different requirements for aircraft on the U.S. register.