AD/BAe 146/141 - State of Design Airworthiness Directives

There are several discrete concepts embedded in the Directive that determine how it operates and what obligations it places on operators and maintainers.

State of Design AD incorporation: The Directive is explicitly directed at ensuring compliance with “State of Design ADs.” The Background explains CASA’s purpose, stating the UK CAA ADs listed in Table 1 “require once-only actions for which the compliance date has passed. CASA has determined that these ADs may be applicable to some Australian aircraft. This Directive is issued to ensure compliance with all State of Design ADs.” The Directive therefore functions as a mechanism to import or enforce the airworthiness directives issued by the State of Design authority, namely the UK CAA, for aircraft of UK design.

Applicability determination: The first required action is an explicit, operator-performed applicability assessment. Requirement 1 places the onus on operators or their maintenance organisations to assess whether each listed UK CAA AD applies to their specific aircraft. This is not a blanket obligation that every aircraft must undergo every task; rather the operator must determine applicability against the ADs’ own applicability criteria.

Mandatory remedial action if applicable: If an AD is applicable and not previously complied with, the operator must undertake the AD’s required action or an EASA-approved later revision. Requirement 2 binds Australian operators to implement the corrective or inspection tasks that the State of Design required, in line with the AD’s mandate or later EASA-approved revisions.

Recognition of EASA-approved AMOCs: The Directive accepts Service Bulletins approved by EASA as Alternative Methods of Compliance to the listed ADs, stating they “are considered acceptable for compliance with the equivalent requirements of this Airworthiness Directive.” That provides an explicit channel for substituted compliance measures, provided they carry EASA approval.

Once-only nature and retrospective trigger: The Background emphasises that the UK CAA ADs were once-only actions with passed compliance dates. CASA’s AD therefore functions as a retrospective enforcement measure, requiring actions that, in many cases, should already have been done under the State of Design regime. The compliance timing provisions make that retrospective requirement operational: if the aircraft does not yet have an airworthiness certificate the actions must be done before certificate issue; if it already has one, the actions must be completed before further flight after 60 days from the Directive’s effective date.

Table 1 as prescriptive manifest: Table 1 is the instrument’s operative manifest of the specific State of Design ADs CASA has identified as potentially applicable. It lists UK CAA AD identifiers, service bulletin references where provided, and concise subject titles such as “Replace bolts on wing rear spar” and “Inspect spars for corrosion and cracking.” The table is therefore the concrete list against which operators must undertake their applicability assessments.

Access point for AD texts: The Directive provides a practical pointer, noting that UK CAA ADs may be accessed via the EASA AD portal at http://ad.easa.europa.eu/. This is the specified source of the full AD texts that the operator must consult to carry out the applicability determination and to establish the exact required corrective actions.

Compliance timing rules: The Directive sets two clear timing triggers, relating to whether an aircraft holds a certificate of airworthiness. For aircraft without a certificate, required actions must be completed before certificate issue; for certificated aircraft, actions must be completed before further flight after 60 days from the Directive’s effective date of 24 September 2010. That framing creates a short, hard compliance window for in-service aircraft.

Issuer and authority: The directive is signed by a CASA delegate, Charles Lenarcic, indicating the action is a formal CASA instrument. The instrument identifies itself as an AD and assigns number 18/2010; that numbering and signature provide traceability as an enforceable CASA directive.

Taken together, these concepts define the Directive as a targeted, time-bound instrument that imports specific State of Design airworthiness requirements into the Australian airworthiness compliance regime, locates responsibility for applicability assessment with operators and maintainers, permits EASA-sanctioned AMOCs, and imposes firm deadlines keyed to certificate status.

The Directive expressly targets operators and maintainers of British Aerospace BAe 146 and Avro 146-RJ aircraft, “all series,” as stated in the Applicability line. That means every Australian-registered BAe 146/Avro 146-RJ type and series falls within the instrument’s scope subject to the applicability assessment each AD requires. Who pays and who acts follows from that identification.

Aircraft operators and owners: Primary financial and operational burden rests with aircraft owners and operators of the BAe 146 series on the Australian register. They must allocate resources to obtain the UK CAA AD texts, conduct the specified applicability assessments for each listed AD, commission and fund whatever inspections, replacements, or modifications are required, and plan aircraft downtime to accommodate the work. The Directive sets the compliance timing and creates potential for aircraft being grounded until tasks are completed for certified aircraft after 60 days.

Maintenance organisations and approved persons: Licensed maintenance organisations, maintenance engineers, and approved persons will typically perform the applicability determination and the technical actions. These organisations must ensure they have the correct service information, EASA approvals where alternative methods are proposed, and traceable records of completion for CASA inspection or for airworthiness certification purposes. If an operator lacks in-house capability, the cost and logistics of outsourcing inspections to suitably qualified organisations become an immediate factor.

CAMO and continuing airworthiness personnel: Where operators use Continuing Airworthiness Management Organisations (CAMOs) or internal continuing airworthiness managers, these personnel are responsible for determining applicability, scheduling, and record-keeping. Their workload increases because the listed UK CAA ADs are multiple and address several discrete aircraft systems.

Certifying authorities and registrars: CASA itself is the issuing authority and therefore the body that will expect to see evidence of compliance. The Directive does not, in its text, specify enforcement actions in detail, but CASA’s role as issuer implicates regulatory oversight and potential follow-up audits. The signature block shows a CASA delegate signed the Directive on 7 September 2010 with an effective date of 24 September 2010.

Third parties and supply chain: Suppliers of replacement parts, approved service bulletins, and repair facilities gain demand as operators seek to comply. Conversely, supply constraints for rarer parts or specialist work can bottleneck compliance. For ADs that require specific parts like bolts or stainless steel pipe for oxygen systems, availability can influence scheduling and cost.

Insurers and lessors: Lessors of BAe 146 aircraft and hull insurers are affected indirectly. A lessor will require evidence of AD compliance before accepting redelivery or completing lease transitions. Insurers will be interested in compliance status because unresolved ADs that effect structural integrity or systems like oxygen and bleed air could expose larger risk.

Potentially unaffected aircraft: The Directive’s Background specifically notes CASA “appreciates that, due to date of aircraft manufacture or aircraft configuration and modification status, some of the ADs listed in Table 1 will not be applicable to any aircraft presently registered in Australia.” Therefore some aircraft may avoid the substantive work if the applicability determination, grounded in the AD texts, excludes them. That shifts emphasis onto precise record-keeping and configuration verification.

In plain allocation of responsibility, operators and their maintenance/CAMO providers must act to determine applicability and carry out required actions where applicable, with CASA expecting compliance and retaining oversight. Financially, the costs of inspections, part replacements, engineering assessments, aircraft downtime, and possibly EASA-approved AMOC procurement fall on operators and owners.

The Directive sets out primary duties, and it also embeds a limited set of rights in the form of accepted alternative compliance routes. All duties and rights flow from the two core Requirements and the compliance timing rules.

Duties

1. Determine applicability: Duty placed on operators and their maintainers to determine whether each UK CAA AD listed in Table 1 applies to their aircraft. The text is explicit: “Determine the applicability of the UK CAA Airworthiness Directives (AD) listed in Table 1.” This requires consulting the full UK CAA AD documents to interpret applicability criteria such as serial number ranges, affected configurations, and prior modifications.

2. Perform required actions if applicable: If an AD is applicable and has not already been accomplished, operators must “perform the actions required by that AD or later EASA-approved revision.” Practically, this creates a duty to carry out mandated inspections, replacements, or modifications specified in the relevant AD or its later EASA-approved revision.

3. Timing obligations: For aircraft without a certificate of airworthiness, the duty is to complete the required actions before issuing that certificate. For certificated aircraft, the duty is to complete required actions before further flight after 60 days from the Directive’s effective date. That creates a firm deadline and the duty to ground or refrain from further flight if the required work has not been performed within the specified window.

4. Record-keeping duty implied: While the Directive does not itemise record-keeping steps, the nature of airworthiness compliance implies operators must document applicability determinations, completed actions, parts used, and any EASA AMOCs relied upon, so evidence is available to demonstrate compliance to CASA.

Rights and options

1. Acceptable EASA AMOCs: The Directive explicitly recognises Service Bulletins approved by EASA as Alternative Methods of Compliance to the listed ADs and treats those SBs “as acceptable for compliance with the equivalent requirements of this Airworthiness Directive.” That grants operators the right to use EASA-approved alternatives instead of strictly following the UK CAA AD text where an AMOC exists.

2. Determination of inapplicability: Operators have the right to determine an AD is not applicable to their aircraft, provided that determination is made against the criteria set out in the AD text. The Directive itself acknowledges some ADs will not apply to certain registrants because of manufacture or modification status. The operator’s applicability assessment, properly documented, can justify non-action where an AD is not applicable.

3. Access to full AD texts: The Directive supplies a practical access route, noting UK CAA ADs are available at ad.easa.europa.eu. Operators therefore have the right, practically speaking, to consult the primary source material on which to base applicability assessments.

Who decides

• The operator/maintenance organisation effectively decides applicability and selects the compliance method, subject to CASA’s oversight. Where an EASA AMOC is to be used, the AMOC’s EASA approval is decisive for acceptance under this Directive. CASA has issued the demand for compliance but delegates the technical determinations and the immediate compliance actions to certificated maintainers and operators.

What changes in behaviour

• Operators must actively review historical ADs, inspect or modify aircraft where required, and institute record-keeping and scheduling changes to accommodate once-only corrective actions. Maintenance planning must incorporate these tasks into forthcoming maintenance events or ground the aircraft until the actions are completed.

The Directive thus erects binding duties to determine applicability and to comply with State of Design remedial actions, while granting the right to rely on EASA-approved alternative compliance paths and to document inapplicability where legitimately established.

The text of this Airworthiness Directive does not itself set out specific penalties, fines, or enforcement procedures in statutory detail. The instrument is framed as an AD with mandatory compliance obligations and contains compliance timing requirements, but it contains no express penalty provision within the text provided. The Directive requires actions be performed “before issue of the certificate of airworthiness” for uncertificated aircraft and “before further flight after 60 days from the effective date” for certificated aircraft; those requirements operate as enforceable compliance obligations rather than standalone penalty rules.

What the Directive does supply that is relevant to enforcement:

• Clear compliance triggers and deadlines: The compliance timing creates a clear, objective standard CASA can use in oversight. For certificated aircraft, the 60-day window from the effective date of 24 September 2010 establishes an unequivocal deadline after which continued flight without completion would be non-compliant with the Directive’s terms.

• Delegated issuer and formalisation: The Directive bears the signature of a CASA delegate and is recorded as AD/BAe 146/141, 18/2010. That formal presentation indicates the instrument is an authorised CASA directive and therefore part of the regulatory framework CASA uses to assess airworthiness conformity.

What is not present in the text and must be noted as a compliance risk:

• No explicit sanctions articulated in the AD text: The instrument does not set out criminal or civil penalties, regulatory sanction processes, or specific enforcement mechanisms in the excerpt provided. It therefore does not, on its face, specify the consequences of non-compliance including fines, prohibition on operations, or administrative enforcement steps. That absence does not mean CASA lacks enforcement powers under other legislation, but the Directive itself does not delineate them.

• Enforcement discretion implicit: Because the Directive does not contain a penalty schedule, enforcement would proceed under CASA’s wider powers and regulatory machinery rather than through penalties embedded in this instrument. The Directive’s deadlines and the fact it is a CASA-issued AD provide a basis for CASA field inspectors or auditors to direct grounding or corrective action, or to escalate under broader regulatory provisions, though the instrument does not spell out those pathways.

Practical enforcement implications for operators

• Non-compliance after the stated deadlines exposes an operator to regulatory scrutiny and likely operational restrictions, given that ADs concern aircraft fitness to fly. Even in the absence of specified penalties in the instrument, CASA can reasonably expect to require evidence of compliance during surveillance, certification processes, or inspections. Operators risk having flights restricted until compliance is demonstrated, and they must bear operational disruption and costs as a result.

• Documentation and proof of compliance will be critical: because the Directive permits EASA-approved AMOCs, operators who choose alternative compliance paths must hold and be able to present the EASA approval documents. For operators who determine an AD is not applicable, records showing why the AD does not apply will be necessary to avoid enforcement action.

In summary, penalties and enforcement are not specified within the AD text but the Directive creates objective compliance obligations and deadlines that CASA can rely upon in exercising its enforcement and oversight roles under Australia’s broader civil aviation regulatory framework. Operators should treat the AD’s requirements as mandatory and maintain contemporaneous documentary evidence to demonstrate compliance or a justified non-applicability determination.

The Directive is explicitly framed as a mechanism to secure compliance with State of Design airworthiness directives, and it therefore sits at the intersection of international and domestic airworthiness regulation. The instrument references UK CAA ADs and EASA approvals, and domestically the instrument is an enforceable CASA AD. The text provides a limited number of explicit cross-references and access points; from there we can describe the interaction mechanisms the Directive creates.

Interaction with State of Design (UK CAA) ADs: The Directive imports the UK CAA ADs listed in Table 1 as the primary technical obligations by requiring operators to “determine the applicability of the UK CAA Airworthiness Directives (AD) listed in Table 1” and to “perform the actions required by that AD or later EASA-approved revision” where applicable. That means the substantive technical requirements of each listed UK CAA AD become the operative source of remedial action, as applied to Australian-registered BAe 146 series aircraft.

Recognition of EASA-approved material: The Directive recognises EASA as a relevant source of revised AD texts and alternative compliance approvals. It explicitly permits “Service Bulletins approved by EASA as Alternative Methods of Compliance (AMOC) to the ADs listed in Table 1” as acceptable for compliance. Mechanically, that means the Directive creates a formal bridge that accepts EASA technical decisions as satisfying CASA’s domestic AD obligations in these instances.

Implications for Australian continuing airworthiness regime: By compelling operators to follow State of Design ADs, the Directive enforces harmonisation between Australian continuing airworthiness outcomes and the airworthiness expectations of the aircraft design authority. Operators must reconcile UK CAA AD applicability criteria with their Australian maintenance programmes, which may require amendments to maintenance schedules, tasks and record-keeping within the Australian continuing airworthiness framework.

Access to AD content: The Directive provides a practical pointer that UK CAA ADs may be accessed at http://ad.easa.europa.eu/. This external linkage indicates operators must consult non-Australian legal instruments to discharge their domestic obligations under the CASA AD. That introduces an element of cross-border legal and technical dependency; operators need to follow the State of Design AD texts and any subsequent EASA-approved revisions.

Certification and airworthiness certificate interaction: The compliance timing rules affect issuance and the validity of the certificate of airworthiness. For aircraft without a certificate, the required actions must be completed before certificate issue. For certificated aircraft, actions must be completed before further flight after 60 days from the Directive’s effective date. That interaction influences the domestic administrative act of issuing or maintaining airworthiness certificates.

No explicit cross-reference to other Australian statutes within the text: The Directive itself does not cite domestic Civil Aviation Regulations, the Civil Aviation Act, or other Australian legislative provisions. Therefore, while CASA’s broader powers and enforcement tools under domestic law likely give effect to the AD, the instrument does not, in the provided text, spell out those linkages.

Practical consequence: operators, maintainers and CAMOs must reconcile three sources when deciding how to act: the CASA AD text (this instrument), the definitive UK CAA AD texts listed in Table 1, and any EASA-approved AMOCs or revisions. With these three sources, operators determine concrete obligations and document compliance for the Australian register. The Directive therefore functions as an integrative instrument, converting foreign State of Design ADs and EASA decisions into enforceable domestic compliance obligations without re-drafting the technical content.

The text provided contains only the initial issuance details for AD/BAe 146/141, number 18/2010. The document records a signature block: “Charles Lenarcic, Delegate of the Civil Aviation Safety Authority,” dated 7 September 2010, and it records the Directive “becomes effective on 24 September 2010.” The AD number assigned is 18/2010. Those items together constitute the published issuance metadata that operators and maintainers would use to identify and trace the requirement.

There are no subsequent amendments, revisions, superseding AD numbers, or corrigenda included within the supplied text. The Directive itself references the possibility of later EASA-approved revisions to the UK CAA ADs listed in Table 1, and it explicitly allows actions required by those later EASA-approved revisions to satisfy the Directive. That means the Directive anticipates technical evolutions in the State of Design or EASA domain, but the Directive text as provided does not itself record any later amendment.

Operational implications of the limited amendment record in the text:

• Static instrument with dynamic references: The Directive as issued is static but points to dynamic, external sources for revised technical content. Operators must therefore monitor the UK CAA/EASA AD portals for later revisions or EASA AMOCs, and they may rely on those later revisions for compliance as permitted by the Directive.

• No domestic amendment log in the instrument: Because the supplied text does not show any domestic amendment, operators should not assume any domestic changes have been made; they should treat the AD as issued on 24 September 2010 and confirm the current status of the listed ADs against CASA’s database or publications for any potential later CASA amendments.

• Traceability and archival: The issuance metadata provided by the Directive is sufficient for archival and certification purposes: AD number 18/2010, effective 24 September 2010, signed 7 September 2010 by a CASA delegate. For auditors or inspectors, that provides a clear point-in-time record of the Directive’s imposition.

If an operator needs to know whether CASA later amended or revoked this AD, that information is not contained in the supplied text. Practitioners should therefore consult CASA’s AD registry, the relevant CASA publications archive, or official CASA communications to confirm whether any amendment, supersession, or revocation has occurred since the 2010 effective date. The Directive itself endorses reliance on EASA approvals for technical revisions, but any change to the Directive’s own requirements or status would be made by CASA through an amendment process not reflected in the instrument text provided.

The instrument text contains no references to judicial decisions, appeal outcomes, or formal disputes about the AD and does not provide any litigation history. There are no cases named, no citations to precedent, nor any procedural commentary regarding appeals against an AD within this Directive. The absence of litigation history in the instrument has several practical consequences and risk points to note.

Implications of the absence of litigation history

• No domestic judicial interpretation recorded: Because the provided AD includes no litigation record, there is no published judicial interpretation of this AD’s scope, enforcement, or interpretation for operators to rely upon. Operators must therefore interpret the AD based on its text, the UK CAA ADs it references, and established practice rather than relying on case law about this specific instrument.

• Unresolved legal questions remain: Issues that commonly generate litigation in AD contexts, such as the proper scope of applicability, the validity of AMOCs, the sufficiency of in-service repairs, or the appropriate remedial measures, have not been decided in any case referenced within this document. If contested, such questions would have to be resolved by administrative processes or courts without prior guidance specific to this AD.

• Administrative vs judicial resolution: In the absence of litigation history, it is likely that disputes would initially be dealt with through administrative channels with CASA, including requests for acceptances, exemptions, or clarifications. The Directive’s explicit acceptance of EASA-approved AMOCs gives a defined administrative pathway for alternative compliance. Operators seeking to rely on a different technical solution would likely pursue an approved AMOC or a formal application to CASA rather than litigate pre-emptively.

Precautionary operational approach in light of no litigation history

• Proactive documentation and engagement: Operators should take care to document applicability assessments and compliance steps exhaustively. If a dispute with CASA arises, robust contemporaneous records will be the primary evidence base, given the absence of case law.

• Seek administrative clarifications where necessary: Where an operator believes an AD is not applicable or seeks to use a compliance method not clearly covered by the AD or by an existing EASA AMOC, the prudent route is to seek written confirmation or an acceptance from CASA, rather than assuming litigable position.

Summary

No litigation history is recorded in the instrument. Absent case law, operators and advisers must rely on the AD text, the UK CAA ADs and EASA materials it references, and administrative processes with CASA to resolve disputes. That increases the importance of administrative engagement and detailed record-keeping because there are no judicial precedents captured in this document to inform contested interpretations of this particular Directive.

This Directive contains several practical traps and pitfalls that can cause compliance failure or operational disruption if not anticipated. The instrument’s text and Table 1 reveal specific areas where errors commonly occur.

1. Applicability assessment workload and errors: Requirement 1 places the onus on the operator to “Determine the applicability of the UK CAA Airworthiness Directives (AD) listed in Table 1.” Each UK CAA AD has its own applicability criteria, which may depend on serial number ranges, configuration options, modifications, or prior repair history. Misreading an AD or failing to match configuration data precisely can lead to either unnecessary compliance costs or missed mandated actions. Operators must obtain and read the full AD texts via the provided EASA AD portal, and have maintenance history and modification records ready for cross-checking.

2. “Once-only” but retrospective: The Background stresses that the UK CAA ADs “require once-only actions for which the compliance date has passed.” That means CASA expects actions that in many cases should already have been completed previously. Operators with incomplete historical records may be unable to prove prior compliance and therefore face the obligation to repeat tasks. Absence of documentary evidence of prior accomplishment is likely to be treated as non-compliance.

3. Tight deadline for in-service aircraft: For aircraft already holding a certificate of airworthiness, the Directive requires completion of applicable actions “before further flight after 60 days from the effective date of this Directive.” The effective date is 24 September 2010. That 60-day window creates a narrow scheduling window that can conflict with maintenance shop capacity, parts availability, and operational commitments, particularly because several ADs concern structural or safety-critical items.

4. Parts availability and specialised work: Table 1 includes tasks such as “Replace bolts on wing rear spar,” “Stainless steel pipe in oxygen system,” and “Inspect spars for corrosion and cracking.” These tasks can require specific replacement parts or skilled structural inspection techniques such as eddy-current or dye-penetrant methods. Parts obsolescence or long lead times for specialised authorised parts may delay compliance. Operators must account for logistical lead times.

5. Service Bulletin references missing or generic: Some rows in Table 1 are annotated “SB not specified” or list only brief SB references. Operators must ensure they obtain the exact service bulletin or the correct technical content referenced by the UK CAA AD to avoid performing the wrong task. Relying solely on the short title in Table 1 without the full AD text risks mis-application.

6. Reliance on EASA AMOCs requires scrutiny: The Directive allows “Service Bulletins approved by EASA as Alternative Methods of Compliance” but only where the AMOC has documented EASA approval. Operators who attempt to rely on equivalence without the formal EASA approval document risk rejection by CASA. Always obtain the EASA approval reference and retain it in the aircraft maintenance file.

7. Configuration-specific ADs: Some ADs target specific configurations, such as “Ex US Air and ex PSA aircraft.” Operators must not apply those ADs indiscriminately across their fleet. Conversely, operators of aircraft that were formerly operated by specific carriers may need to verify trace histories to determine whether a given AD applies.

8. Record-keeping and certification after work: The Directive does not prescribe specific record formats, but compliance will be judged on documentary evidence. Failure to update maintenance records, logbooks, and the approved maintenance release documentation can render an otherwise completed action non-evidenced.

9. Interaction with airworthiness certificate issuance and transfer: For aircraft in importation or transfer, the requirement to complete applicable actions “before issue of the certificate of airworthiness” must be planned into the import acceptance schedule. Missing this step can delay release of the aircraft into service.

10. No penalties spelled out in the text: Because the instrument does not explicitly set penalties, operators might misinterpret enforcement as informal. That is a gotcha; CASA retains enforcement authority under broader legislation and the Directive’s deadlines will be enforceable in inspections or audits. Do not assume leniency; treat the AD as mandatory.

In practice, operators should treat the Directive as imposing a high administrative and technical compliance standard, requiring precise applicability checks, robust documentary evidence of prior work, or timely completion of new tasks, with particular attention to obtaining and retaining any EASA-approved AMOC documentation.

Compliance requires a structured, documented process that aligns with the Directive’s two-step requirement and the timing rules. Below is a practical, sequenced compliance checklist grounded in the Directive’s text and Table 1.

1. Identify affected aircraft and gather records

   • List all BAe 146 and Avro 146-RJ aircraft on the Australian register that you operate or manage, including serial numbers, variants, and full modification history.
   • Assemble complete maintenance records, previous AD compliance records, service bulletin incorporation records, and any modification approval documents for each airframe. The Directive’s Background explicitly envisages that some ADs may not apply depending on manufacture date or configuration; the evidence to support a non-applicability determination will come from these records.

2. Obtain the full UK CAA AD texts

   • Use the source referenced in the Directive, http://ad.easa.europa.eu/, to retrieve the full text of each UK CAA AD listed in Table 1. The short titles in Table 1 are not sufficient; you must read the AD’s applicability clause, required actions, compliance times, and any allowable methods of compliance. The Directive instructs operators to “Determine the applicability of the UK CAA Airworthiness Directives (AD) listed in Table 1.”

3. For each AD, perform an applicability assessment

   • Compare each AD’s applicability criteria to each aircraft’s serial number, configuration, equipment lists, and modification status. Document the rationale and cite specific lines from the AD for your determination. If an AD’s applicability depends on prior embodiment of certain service bulletins or modification kits, verify whether those were previously embodied.

4. Determine prior accomplishment

   • For ADs found applicable, confirm whether the actions have already been performed. The Directive requires performing actions “if ... applicable and has not been previously accomplished.” Retain documentary evidence of prior accomplishment such as maintenance release certificates, signed logbook entries, or equivalent records.

5. Choose compliance method

   • If work remains to be done, you have two paths permitted by the Directive: a) Perform the actions specified directly by the UK CAA AD or by a later EASA-approved revision; or b) Apply an EASA-approved AMOC as set out in a Service Bulletin approved by EASA. The Directive states that such service bulletins “are considered acceptable for compliance.”

6. Plan and schedule the work

   • For aircraft without a certificate of airworthiness, ensure the required work is completed before the certificate is issued.
   • For certificated aircraft, schedule the work so it is completed before further flight after 60 days from the Directive’s effective date of 24 September 2010. As that date is in the past, in practical contemporary terms the operator should ensure the work is completed immediately and that records show it was completed before any flight after those dates.

7. Execute the required inspections/modifications

   • Engage suitably rated maintenance organisations or licensed engineers to perform inspections, replacements, or repairs exactly in accordance with the AD text or the accepted EASA AMOC. Use certified parts and approved procedures. For structural inspections or critical-system work, ensure appropriate inspection techniques and non-destructive testing methods are qualified.

8. Record completion and certification

   • Update the aircraft maintenance records, logbooks, and continuing airworthiness documentation to show the AD applicability determination, the work performed, parts fitted (including part numbers and STC references where applicable), and references to the AD and any EASA-approved AMOC used.
   • Where applicable, have a formally authorised certifying staff member sign off the maintenance release or equivalent document, and file copies with the aircraft’s continuing airworthiness records.

9. Retain EASA approval evidence where an AMOC is used

   • If using a Service Bulletin approved by EASA as an AMOC, retain the EASA approval documentation and cross-reference it in the aircraft records. The Directive explicitly makes EASA-approved AMOCs acceptable; that acceptance rests on having the approval evidence available.

10. Prepare for CASA oversight and audits

• Given that this is a CASA AD, be prepared to present the applicability assessments, completed work records, and EASA approval documents to CASA upon request. If there is any uncertainty in applicability or compliance method, consider engaging CASA early to seek written confirmation or guidance.

11. For imports and transfers

• If the aircraft is in the process of being imported or undergoing change of registration, ensure applicable ADs are complied with before CASA issues a certificate of airworthiness, as the Directive states required actions must be completed before certificate issue for uncertificated aircraft.

12. If an AD is genuinely inapplicable, document why

• The Directive acknowledges some ADs may not be applicable due to manufacture date or configuration. If you determine an AD is inapplicable, maintain a documented determination citing the exact lines in the UK CAA AD that justify non-applicability and include supporting aircraft records so that CASA can verify the basis for your decision.

If any doubt exists about interpretation, scope, or whether a proposed alternative meets the Directive’s requirements, seek formal advice from CASA or pursue an EASA-approved AMOC where appropriate. The Directive gives operators some latitude via EASA AMOCs, but the burden is on the operator to establish that the chosen method fully satisfies the AD’s intent and to retain the paperwork proving it.

In sum, compliance is a paperwork-intensive, technically specific process. The operator must: source the original AD texts, conduct and document applicability checks, perform or document prior accomplishment of required actions, use EASA-approved AMOCs if available, and maintain contemporaneous, auditable records showing compliance prior to certificate issue or within the Directive’s flight-restriction timing.