AD/BEECH 36/52 - Circuit Breaker Toggle Switches

The core legal and technical mechanics of this AD are: applicability, mandatory replacement, installation prohibition, method of compliance, a compliance window, and acceptance of FAA-approved AMOCs to RAC service bulletin revisions.

Applicability: The Directive applies only to those aeroplane models and serial-number ranges listed in Table 1, and only where any circuit breaker toggle switch with P/N 35-380132-1 through 35-380132-53 is installed (Applicability; Table 1). Table 1 lists model identifiers (A36, A36TC and B36TC) and specific serial-number ranges (for example, E-185 through E-3629 and E-3631 through E-3635; EA-1 through EA-695). The Directive’s applicability is therefore both model- and configuration-dependent: the presence of the listed P/N in the aeroplane is a precondition for the Directive to bite.

Mandatory replacement (Requirement 1): If the older P/Ns are present, the AD mandates replacement with improved P/Ns 35-380132-61 through 35-380132-113, “as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24-3735, Issued: August 2005” (Requirement 1). The AD therefore delegates the technical method and detail of the replacement procedure to the referenced RAC service bulletin.

Installation prohibition (Requirement 2): The AD prohibits installing the older P/Ns (35-380132-1 through -53) on any aeroplane as an initial fit or as a replacement spare (Requirement 2). This is not merely a one-off retrofit requirement; it is a continuing ban on future fitting of the affected parts.

Compliance timeline and effective date: The AD sets the deadline for Requirement 1 at “within the next 24 months after the effective date of this Directive” and records that the Directive becomes effective on 25 September 2008 (Compliance; Effective date). The Directive expressly allows for “prior accomplishment” , that is, if the RAC SB work was already done before the AD, the operator is not required to repeat it (Background and Requirement 1 text).

Method flexibility via AMOC: The Directive accepts later revisions of the RAC service bulletin if those revisions are approved by the FAA as an Alternate Method of Compliance to FAA AD 2008-13-17 (later revisions/AMOC note). The AD thus permits an FAA-approved pathway for alternative compliance procedures, but conditions acceptance on FAA approval of the specific SB revision as an AMOC.

Risk basis: The background records FAA reporting of overheating of certain circuit breaker toggle switches across several Beechcraft models, which could lead to smoke in the cockpit and inability to turn off the switch (Background). The AD states it “follows the intent of the FAA Directive” but modifies timing and allows prior accomplishment (Background).

Record and administrative context: The Directive was posted for public comment on CASA’s internet site on 9 July 2008 and, according to the text, “no comments or objections have been received” as of the date the Directive was made (Background). The Directive is signed by a CASA delegate (James Coyne) and dated 8 August 2008.

Together these elements create a compliance package: inspect applicability, effect the approved parts replacement per RAC SB 24-3735 (or an FAA-approved AMOC), and observe the ongoing prohibition on fitting the older P/Ns, all within the stated time window unless prior accomplishment can be demonstrated.

Operators and owners of the specified Beechcraft 36 (Bonanza) series aeroplanes listed in Table 1 are the primary parties affected. The Directive’s applicability clause limits the legal obligation to aeroplanes of the listed models and serial-number ranges that have any circuit breaker toggle switch with P/N 35-380132-1 through 35-380132-53 installed (Applicability; Table 1). Aircraft that do not have those part numbers installed, or that are not within the serial-number/model ranges in Table 1, are not subject to the Directive as written.

Maintenance organisations, engineers and certificated aircraft maintenance personnel who perform the replacement work will be operationally affected because the Directive explicitly requires replacement “as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24-3735, Issued: August 2005” (Requirement 1). That links the required method of work to a manufacturer’s service bulletin rather than prescribing detailed technical steps in the Directive itself, so maintenance providers must follow the SB or an FAA-approved alternate method.

Parts suppliers and spare-part inventories are also affected. Requirement 2 prohibits the installation of the older P/Ns “as an initial fit or as a replacement spare” (Requirement 2). That prohibition directly constrains what parts can be sold, stocked and installed in the affected aeroplanes. Sellers and logistics managers supplying parts to operators of the affected models will need to stop distributing or provisioning those specific P/Ns for use on the affected fleet, assuming the prohibition is binding for them under applicable regulatory enforcement regimes.

Regulators and delegated CASA officials are implicated administratively; the Directive cites FAA AD 2008-13-17 and accepts FAA-approved AMOCs (later revisions/AMOC note), establishing a cooperative compliance route that links CASA’s Directive to FAA administrative approvals. The AD itself is issued by CASA (Delegate James Coyne) and became effective on 25 September 2008 (signature and effective date).

Passengers and third parties are indirectly affected because the Directive addresses a safety risk (overheating leading to smoke in the cockpit and inability to turn off the switch). The Directive’s mechanics aim to reduce that operational hazard for flights operated in affected aircraft, but no passenger-specific obligations or procedures are set out in the text.

Finally, the Directive references earlier work by the manufacturer (RAC SB 24-3735, Issued: August 2005) and allows for prior accomplishment. Where operators have already carried out the SB work before the Directive, they are explicitly exempted from repeating it (Background; Requirement 1: “Unless previously accomplished”). For those operators, the administrative implication is that they must be prepared to demonstrate that prior compliance if required by the enforcing authority; the Directive itself does not set out documentary requirements but the exemption logically depends on proof of prior accomplishment.

Duties imposed by the Directive are specific and circumscribed. The principal duties are:

• Replace affected circuit breaker toggle switches: For aeroplanes within the Table 1 applicability that have any circuit breaker toggle switch P/N 35-380132-1 through 35-380132-53 installed, the operator must replace all such switches with improved P/Ns 35-380132-61 through 35-380132-113, “as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24-3735, Issued: August 2005” (Requirement 1). The duty is unconditional unless the work has already been performed prior to the Directive (“Unless previously accomplished” in the Requirement 1 text).

• Do not install older part numbers: The operator, and any maintenance personnel acting on the aeroplane, must not install circuit breaker toggle switches P/N 35-380132-1 through 35-380132-53 on any aeroplane as an initial fit or as a replacement spare (Requirement 2). This is an ongoing prohibition that survives the immediate replacement activity.

• Observe the compliance timeframes: Requirement 1 must be completed “within the next 24 months after the effective date of this Directive” and the Directive became effective on 25 September 2008, so the deadline for replacement is within 24 months of that date (Compliance; Effective date). Requirement 2’s compliance note instructs that the installation prohibition must be observed “before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1” (Compliance for Requirement 2).

Rights and options recognised by the Directive:

• Right to rely on prior accomplishment: The Directive explicitly allows that if the RAC SB replacement was performed before the AD, the operator is not obliged to repeat the work (Requirement 1: “Unless previously accomplished”; Background). This creates a practical right to an exemption from redundant action where the mandated remedy has already been implemented.

• Option to use FAA-approved AMOCs to later RAC SB revisions: The Directive states that later revisions of RAC SB 24-3735 are acceptable for compliance if those revisions are approved by the FAA as an Alternate Method of Compliance to FAA AD 2008-13-17 (later revisions/AMOC note). That provides an administrative pathway for using updated manufacturer procedures, provided the FAA has approved them as AMOCs , the operator’s option is contingent on FAA approval.

Non-specified matters in the Directive that affect duties and rights:

• The AD does not set out administrative requirements such as documentation, forms or record-keeping procedures for demonstrating compliance or prior accomplishment. It also does not specify who at the operator or maintenance organisation must sign off the work, nor does it set out penalties for non-compliance within the AD text itself. The Directive’s silence on these matters means operators must look to applicable secondary regulations, internal procedures or CASA enforcement practices to understand evidentiary and administrative obligations; the AD itself confines its mandate to the technical actions and timeframes described.

Practical duty implications:

• The replacement duty requires obtaining the improved P/N parts and performing the work according to the RAC SB. That creates procurement and maintenance scheduling obligations for operators. The installation ban requires supply-chain changes and preventative compliance actions to ensure that the older P/Ns are not fitted in the future.

In sum, the Directive imposes a tangible maintenance obligation on owners/operators of the listed aircraft where the listed parts are installed, establishes an ongoing prohibition against the continued use or reinstallation of the older P/Ns, and offers limited administrative flexibilities (prior accomplishment and FAA-approved AMOCs).

The Directive text itself does not specify penalties, fines, or particular enforcement mechanisms in statutory detail. The AD states the technical requirements, the applicability, the compliance periods, and acknowledgements regarding FAA AMOCs and prior accomplishment, but it does not include an express penalties clause or procedural enforcement section within the text provided.

What is explicit in the AD is its effective date and the statement that the AD “becomes effective on 25 September 2008” (Compliance; Effective date). The presence of an AD issued by the Civil Aviation Safety Authority (CASA) and signed by a delegate (James Coyne) conveys an authoritative regulatory prescription; however, the Directive text as supplied does not itself set out the legal consequences for failing to comply, nor does it cross‑reference particular enforcement provisions or penalty schedules.

Because the AD does not state enforcement processes or sanctions within its own text, operators should be aware of two practical points grounded in the AD’s mechanics:

• The AD imposes mandatory technical obligations (the replacements and the ongoing installation prohibition). To demonstrate compliance or to rely on prior accomplishment, operators will need credible evidence of the replacements or of prior work carried out in accordance with RAC SB 24-3735 or an FAA‑approved AMOC. The AD’s allowance that prior accomplishment negates the replacement requirement implicitly requires an ability to establish that prior work actually occurred; while the AD does not prescribe the form of such proof, compliance will likely require documentation or maintenance records that show the RAC SB work was completed prior to the AD coming into force.

• The AD accepts FAA-approved AMOCs as acceptable for compliance with equivalent requirements. That acceptance creates an administrative route for operators to seek an alternative method of compliance; however the AD conditions this on FAA approval of a later SB revision as an AMOC, thereby tying acceptance to an external authority’s administrative action (later revisions/AMOC note). Any operator seeking to rely on an AMOC must obtain evidence of the FAA approval.

Because the Directive text does not specify enforcement mechanisms or penalties, readers must not infer particulars beyond what the AD contains. The AD should be read together with the broader statutory and regulatory framework under which CASA issues ADs, and operators seeking certainty about enforcement consequences should consult the applicable aviation safety statutes, regulations, and CASA guidance or contact CASA directly. The AD itself remains a binding technical prescription on the affected aircraft as of its effective date, but the instrument’s supplied text does not include an internal enforcement or penalty schedule.

The Directive explicitly situates itself in relation to the United States Federal Aviation Administration (FAA) regulatory action and to a manufacturer’s service bulletin. The AD refers to FAA AD 2008-13-17 Amdt 39-15580 (Note), and it states that later revisions of the RAC service bulletin SB 24-3735 that are “approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2008-13-17, are considered acceptable for compliance with the equivalent Requirements of this Directive” (later revisions/AMOC note). This creates an explicit cross‑reference to FAA AD 2008-13-17 and to FAA administrative approvals.

Implications of that cross‑reference:

• Conformity with FAA AMOCs: The AD allows CASA’s technical prescription to be met by following an AMOC approved by the FAA for the FAA AD. Practically, that means operators who obtain FAA approval of a later RAC SB revision as an AMOC can use that FAA approval as the compliance basis for CASA’s AD. The AD therefore imports FAA administrative decisions into the local compliance regime for these specific alternatives.

• Relationship with RAC service bulletins: The Directive prescribes the RAC Recommended Service Bulletin SB 24-3735 (Issued: August 2005) as the specified method for accomplishing the replacement (Requirement 1). By tying the required technical method to a manufacturer’s SB, the AD interacts with the body of technical standards promulgated by the manufacturer. Where the RAC SB is updated, operators may rely on later revisions only if the FAA approves the revision as an AMOC to the FAA AD; the CASA AD does not unilaterally accept later SB revisions without FAA administrative approval (later revisions/AMOC note).

Limitations and silence in the AD regarding other laws:

• The AD does not reference domestic enforcement statutes, administrative procedures or penalty provisions in CASA or aviation safety law. It therefore does not in its own text specify criminal or civil penalties, or administrative enforcement steps. To understand interactions with domestic enforcement instruments, readers must consult the broader legislative and regulatory framework under which CASA issues ADs; the Directive itself confines its scope to technical prescriptions and cross‑references to the FAA and RAC SB.

• The AD does not state any interaction with commercial law, supply‑chain regulation, or import/export controls that might affect the procurement of replacement parts. The installation prohibition (Requirement 2) implies commercial consequences for part suppliers and maintainers, but the AD text does not set out direct obligations or sanctions for suppliers under commercial statutes.

Other practical interactions:

• Timing divergence from FAA: The AD notes it “extends compliance by 13 months until 25 September 2010, the final compliance time required by the FAA was 6 August 2009” (Background). The CASA Directive therefore alters the timeline (extends it) relative to the FAA AD. That divergence means operators flying in different regulatory jurisdictions may face different compliance windows; the CASA AD explicitly records that divergence in its background text.

• Evidence of prior accomplishment: Because the AD allows prior accomplishment of the RAC SB to satisfy Requirement 1, the interaction with record‑keeping and maintenance‑release rules under relevant aviation safety law and maintenance standards will be practical. The AD itself does not lay out the documentary standard, but the existence of the exemption creates an interaction point with laws and regulations governing maintenance records and certification.

In summary, the Directive interacts with other laws and administrative instruments mainly by: (a) mandating compliance via a manufacturer’s service bulletin; (b) expressly accepting FAA-approved AMOCs as acceptable alternatives; and (c) diverging from the FAA on the compliance timeframe. It does not, within its text, set out domestic enforcement mechanisms or penalties, so interaction with enforcement and procedural law must be drawn from the broader regulatory environment rather than from the AD itself.

The AD itself contains limited self-referential amendment history and describes only a small set of temporal and procedural adjustments relative to the FAA action and to the RAC service bulletin. The text records the following relevant temporal and amendment-related points.

• Manufacturer’s service bulletin date: The Directive specifies RAC Recommended Service Bulletin SB 24-3735, Issued: August 2005, as the required technical method for replacing affected switches (Requirement 1). The AD notes that this SB was issued in 2005, which is relevant to the AD’s allowance for prior accomplishment (Background).

• Prior accomplishment allowance: The Directive is “revised to allow prior accomplishment, as the RAC service bulletin was issued in 2005 and may have already been accomplished” (Background). This indicates that the AD’s drafters intentionally included language to exempt aeroplanes on which the RAC SB replacement had already been carried out prior to the AD’s issuance.

• Compliance timeline modification relative to FAA: The AD “extends compliance by 13 months until 25 September 2010; the final compliance time required by the FAA was 6 August 2009” (Background). This is a concrete departure from the FAA AD’s final compliance date: CASA pushed the deadline outward by 13 months relative to the FAA timeline. The CASA AD’s own compliance deadline remains the AD’s effective date plus 24 months (Compliance; Effective date), which equates to a completion date by 25 September 2010.

• Relationship to FAA AD: The Directive records that FAA AD 2008-13-17 Amendment 39-15580 is the corresponding FAA action (Note). Later revisions of RAC SB 24-3735 that are approved by the FAA as AMOCs to FAA AD 2008-13-17 are “considered acceptable for compliance with the equivalent Requirements of this Directive” (later revisions/AMOC note). That language creates a standing cross-acceptance for FAA AMOCs and thus a potential mechanism for future variations in the accepted technical method, but only to the extent the FAA actually approves a specific revision as an AMOC.

• Public comment process: The AD states a draft version was posted for public comment on the CASA internet site on 9 July 2008 and that “no comments or objections have been received by CASA” as of the date the Directive was made (Background). This documents the administrative process used and indicates the AD was not amended in response to public comment, at least according to the AD’s summary.

• Effective date and signature: The AD was signed by James Coyne, Delegate of the Civil Aviation Safety Authority, on 8 August 2008, and the AD “becomes effective on 25 September 2008” (signature and effective date). The AD is identified as AD/BEECH 36/52, 10/2008.

No further amendment history or iterations of the CASA AD itself are recorded in the supplied text. The AD does not include any subsequent amendments, revocations, supersessions or consolidations within the provided material. The text does, however, create a procedural channel for later SB revisions to be accepted via FAA AMOC approvals, which is a conditional mechanism for future method variations without an immediate CASA amendment, subject to FAA action.

The supplied Directive text does not reference any litigation, judicial review, or court proceedings concerning the AD. It records procedural administrative facts (posting a draft for public comment, signature by a CASA delegate) and notes that “no comments or objections have been received by CASA” as of the date the Directive was made (Background), but it does not indicate any disputes, appeals, or litigation arising out of the AD.

Because the Directive itself contains no litigation history, there are no cases, administrative appeals, or decisions cited in the text that would illuminate contested points of law or fact about this specific AD. The AD does reference FAA AD 2008-13-17 (Note) and accepts FAA-approved AMOCs for the RAC service bulletin revisions, but it does not recount litigation connected to the FAA action either.

For parties interested in whether disputes or enforcement actions have occurred under this AD, the AD provides no evidence in the text supplied. Any subsequent litigation, enforcement proceedings, or administrative appeals would lie outside the document’s content and are not recorded here. To establish whether any litigation or contested administrative process occurred after the making of the Directive, readers would have to consult CASA records, court registries, or enforcement files external to this AD text.

The Directive contains a number of drafting and practical features that may surprise operators and maintenance providers if they read the text quickly. The following points identify those potential “gotchas” by reference to the Directive text.

1. Applicability requires both model/serial and installed part: The AD applies only to the models and serial-number ranges listed in Table 1 and only if any circuit breaker toggle switch with P/N 35-380132-1 through -53 is installed (Applicability; Table 1). Some readers might assume the AD applies to all A36 variants irrespective of installed parts; the AD is explicit that the presence of the listed P/Ns is a condition precedent. Consequently, operators should check the part numbers actually fitted, not merely assume applicability based on model type alone.

2. “Unless previously accomplished” changes the compliance burden into an evidentiary issue: Requirement 1 is qualified by “Unless previously accomplished,” which permits operators who have already implemented RAC SB 24-3735 to avoid repeating the work (Requirement 1; Background). However, the AD does not specify what evidence constitutes satisfactory proof of prior accomplishment. Operators who cannot substantiate prior compliance with maintenance records risk being treated as non-compliant if challenged. The AD itself is silent on documentary standards.

3. Requirement 2 is an ongoing installation ban, not just a one-time prohibition: Requirement 2 states that “Circuit breaker toggle switches P/N 35-380132-1 through 35-380132-53 may not be installed ... as an initial fit or as a replacement spare” (Requirement 2). This is not merely a retrofitting mandate; it forbids future installation of the affected P/Ns. Organisations stocking spares or performing maintenance must adjust their procurement and spare inventory policies accordingly.

4. Ambiguity in the “before further flight” phrasing: The compliance note for Requirement 2 reads “Before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1” (Compliance for Requirement 2). Read literally, that could be interpreted to mean that after replacement in accordance with Requirement 1, the operator must ensure the old P/N is not installed before the next flight, which is logically redundant with the prohibition. Practically, the intended meaning appears to be that after replacement, the aircraft must not depart with any of the old P/Ns installed; operators should treat the prohibition as immediate and ongoing. The AD does not clarify the intended precise sequencing or any related ferry-flight exceptions.

5. Acceptance of later SB revisions is conditional on FAA AMOC approval only: The AD allows later revisions of the RAC SB to be used for compliance only if those later revisions are “approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2008-13-17” (later revisions/AMOC note). This is not an open-ended acceptance of manufacturer updates; it conditions acceptance on FAA administrative approval. Operators cannot unilaterally adopt later SB revisions without an FAA AMOC.

6. CASA’s timeline divergence from the FAA: The AD explicitly extends the compliance deadline by 13 months relative to the FAA’s final compliance time and notes that the FAA’s final compliance time was 6 August 2009 whereas the CASA Directive’s effective compliance extends until 25 September 2010 (Background). Operators that operate internationally or across jurisdictions may need to navigate differing compliance deadlines if they are subject to multiple authorities.

7. No penalties or enforcement mechanics are specified in the AD text: Readers seeking clarity on sanctions for non-compliance will not find them in the Directive. The AD mandates action but does not prescribe the enforcement process or penalties in its own text, so parties must look to the broader regulatory framework for enforcement details.

8. The AD’s applicability table is precise and limited: Table 1 lists specific serial ranges (for example, E-185 through E-3629 and E-3631 through E-3635; EA-1 through EA-695). Small errors in serial-number interpretation could misclassify an aircraft as inapplicable when it is applicable, or vice versa. Operators must cross-check serials carefully.

9. The AD cross-references FAA AD 2008-13-17 but does not reproduce it: The Directive’s Note cites FAA AD 2008-13-17 Amdt 39-15580 but does not include its text. An operator relying on AMOCs or seeking to understand differences between the FAA AD and the CASA Directive will need to obtain the FAA AD text separately to compare obligations and timelines.

10. The AD recognises manufacturer work dating from 2005: Because RAC SB 24-3735 was issued in August 2005, many operators may already have done the work. Failure to have clear historical records could cause unnecessary repeat work if the operator cannot demonstrate prior accomplishment.

These gotchas are matters of legal drafting, administrative interaction, and practical operations; they arise directly from the AD text and its specific phrasing rather than from external law.

The Directive sets out a narrow and concrete compliance pathway. The following steps, grounded in the AD text, explain what an operator should do to comply with the AD’s requirements.

1. Determine applicability precisely. Consult Table 1 and the “Applicability” wording. The AD applies only to The Beech A36, A36TC and B36TC models listed in Table 1 and only to aeroplanes that have any circuit breaker toggle switch with P/N 35-380132-1 through 35-380132-53 installed (Applicability; Table 1). Verify both the model/serial range and the actual installed part numbers for each aeroplane in the operator’s fleet.

2. Establish whether prior accomplishment applies. The AD states “Unless previously accomplished, replace...” (Requirement 1) and records that RAC SB 24-3735 was issued in August 2005 (Requirement 1; Background). If the RAC service bulletin work was completed before the AD’s effective date, that prior accomplishment satisfies Requirement 1. To rely on this exemption, assemble maintenance records or other credible evidence that demonstrate the SB work was done prior to the AD. The AD itself does not specify the form of proof, so maintain complete records as a practical compliance measure.

3. If replacement is required, use the specified method. The Directive requires replacement “as specified in Raytheon Aircraft Company (RAC) Recommended Service Bulletin SB 24-3735, Issued: August 2005” (Requirement 1). Obtain and follow RAC SB 24-3735 for the technical procedure, parts compatibility information and any special tests or checks the SB prescribes. Employ certificated maintenance personnel or an appropriately authorised maintenance organisation to carry out the work in accordance with the SB.

4. Use the improved part numbers specified. Replace P/Ns 35-380132-1 through 35-380132-53 with improved P/Ns 35-380132-61 through 35-380132-113, as applicable (Requirement 1). Ensure procurement and parts management procedures are updated to source the correct improved P/Ns.

5. Observe the installation prohibition. Do not install the older P/Ns 35-380132-1 through 35-380132-53 on any aeroplane as an initial fit or as a replacement spare (Requirement 2). Adjust spare parts inventories, sales practises, and maintenance planning so that the older P/Ns are not used on the fleet subject to the AD. Communicate this prohibition to maintenance providers and supply-chain partners.

6. Respect the compliance timeframes. Requirement 1 must be completed within 24 months after the Directive’s effective date, which is 25 September 2008 (Compliance; Effective date). The AD’s text indicates the intended final compliance time is extended compared with the FAA AD, so apply the AD’s stated 24‑month timeframe. Requirement 2 should be enforced immediately upon replacement and thereafter: the AD notes compliance for Requirement 2 is “before further flight after the circuit breaker toggle switch has been replaced in accordance with Requirement 1” (Compliance for Requirement 2), which operatively means no aircraft should depart with the older P/Ns installed after the replacement process.

7. Consider AMOCs only if FAA-approved. If RAC issues later revisions of the SB and you want to use those revisions, confirm whether the FAA has approved the later revision as an AMOC to FAA AD 2008-13-17. The AD accepts such FAA-approved AMOCs for compliance with the equivalent CASA Requirements (later revisions/AMOC note). Do not rely on later SB revisions unless there is an FAA AMOC approval for that SB revision.

8. Document the work and retain evidence. Although the AD does not prescribe documentation formats, operators should keep clear maintenance records showing the part numbers removed and installed, dates of replacement, and reference to RAC SB 24-3735 (or to the FAA‑approved AMOC if used). The AD’s “unless previously accomplished” exemption requires the operator to be able to show the work was done prior to the AD; record retention best practice will support that.

9. Coordinate with maintenance providers and parts suppliers. Notify maintenance organisations that the RAC SB method is the specified method and that the older P/Ns are banned for initial fit or replacement spare. Update procurement systems to source and record the approved improved P/Ns.

10. Audit fleet compliance. Perform a fleet check to identify any aeroplanes subject to the AD and confirm replacements or prior accomplishment across the fleet. Maintain a compliance register mapping each aircraft to its status (not installed, prior accomplishment, replaced per SB, or replaced via FAA-approved AMOC).

The AD’s text supplies the mandatory technical actions and the compliance timetable. Operators should follow the AD literally: replace affected P/Ns per RAC SB 24-3735 unless prior accomplishment can be shown, and cease any installation of the older P/Ns. Where ambiguity exists (for example, on evidence standards), maintain comprehensive records and, if necessary, seek clarification from CASA or rely on an FAA AMOC where applicable and evidenced.