AD/CAP 10/5 Amdt 1 - Front Tank Support Strap

The directive rests on a small set of explicit concepts and mechanical rules set out in the source text. Applicability is narrow: Model CAP 10B aircraft, all serial numbers. The specific aircraft component at issue is the front fuel tank support strap, part number CAP10-70-08-01. The prior established life limit was 4,000 hours; the directive mandates a new life limit of 2,000 hours to be recorded on the component history card or equivalent record. The AD directs operators to amend their maintenance programmes to reflect this new airworthiness limitation, referencing APEX Aircraft Service Bulletin No. 040102 Revision 1 or a later EASA-approved revision as the maintenance direction to follow. Where a strap’s installed hours cannot be established, the directive establishes a default rule: use the total hours accumulated on the aircraft to determine the strap’s life for compliance purposes. The AD differentiates three factual situations and ties each to a compliance timing requirement: (1) straps with recorded hours below the new 2,000 hour limit must have the life limit reduced on the record and maintenance programme amended before further flight after 20 November 2007; (2) straps that have exceeded 2,000 hours but are below 2,500 hours on the effective date must be replaced within 100 hours or six months; and (3) straps that have exceeded 2,500 hours but are below 4,000 hours on the effective date must be replaced within 25 hours or one month. The directive explicitly cross-references EASA AD 2007-0285 (Note 2) and identifies the immediate safety rationale: discovery of a damaged strap that had accumulated under 4,000 hours led to shortening the life limit so that fatigue cracks are less likely to develop before the established safe life is reached. The document is framed as an amendment (Amendment 1) to a previously issued AD, and it becomes effective on 20 November 2007. These are the core mechanical constraints the operator must observe; the document does not set out additional technical specifications beyond the part number, the new life limit, the replacement triggers, the compliance windows, and the referenced service bulletin.

The directive directly affects operators of Avions Mudry CAP 10B aircraft (applicability: Model CAP 10B aircraft, all serial numbers). That includes any registered owner, air operator certificate holder, maintenance organisation, or individual owner-operator who maintains aircraft records and maintenance programmes for CAP 10B types. The directive identifies the affected component by manufacturer part number CAP10-70-08-01, so maintenance providers who procure or certify replacement straps are also affected, because they must supply conforming hardware and record replacements in the component history card or equivalent records. Responsibility falls to the operator to amend the maintenance programme to "comply with this new airworthiness limitation" and to ensure component records reflect the reduced life limit, per Requirement 1. Where an operator cannot establish accumulated hours on a particular strap, the directive instructs the operator to use the aircraft’s total accumulated hours for the determination (Note 1), which affects record-keeping practices and imposes a substantive rule when component-level history is absent. The directive also affects scheduling and operational planning: aircraft with straps in the 2,000-2,500 hour band must be scheduled for replacement within the specified 100 hour or six month window, and those in the 2,500-4,000 hour band must be scheduled within the shorter 25 hour or one month window. The Civil Aviation Safety Authority, through its delegate (the document is signed by David Villiers), is the issuing authority; the directive thus affects regulated parties subject to CASA’s airworthiness directions. The AD references an external source, APEX Aircraft Service Bulletin No. 040102 Revision 1 or later EASA-approved revision, and EASA AD 2007-0285, so organisations that rely on or adopt that service bulletin as part of their continuing airworthiness programmes are indirectly affected by any technical content or revisions of that bulletin that are EASA-approved. The source does not list insurers, airports, passengers or third parties; its obligations are framed as duties for operators and their maintenance records and programmes. The document’s effective date, 20 November 2007, creates immediate obligations for affected operators as described in the compliance column.

The directive sets a small number of concrete duties and limited procedural flexibilities, stated in the source.

Duties:

• Reduce the life limit for front fuel tank support strap part CAP10-70-08-01 from 4,000 hours to 2,000 hours on the component history card, or equivalent record, and amend the operator’s maintenance programme to reflect the new airworthiness limitation. This is Requirement 1 in the source.
• Replace any strap that, on the effective date, has already exceeded 2,000 hours but accumulated less than 2,500 hours (Requirement 2).
• Replace any strap that, on the effective date, has already exceeded 2,500 hours but accumulated less than 4,000 hours (Requirement 3).

Timing duties (compliance windows):

• The life-limit reduction and maintenance-programme amendment must be performed before further flight after 20 November 2007 (Compliance 1).
• Replacement for straps in the 2,000-2,500 hour band must be completed within 100 hours time in service or six months after 20 November 2007, whichever occurs first (Compliance 2).
• Replacement for straps in the 2,500-4,000 hour band must be completed within 25 hours time in service or one month after 20 November 2007, whichever occurs first (Compliance 3).

Procedural flexibilities and specific rules:

• Where an operator cannot establish the accumulated hours on a given fuel tank support strap installed on an aircraft, the directive instructs that the total hours accumulated on the aircraft must be used for the determination of the strap’s time for compliance purposes (Note 1). That is an explicit tolerance for incomplete component-level history, but it imposes a specific deterministic rule rather than discretion.
• The directive references APEX Aircraft Service Bulletin No. 040102 Revision 1, "or later EASA approved revision", allowing operators to comply to the later EASA-approved revision of that service bulletin, which permits following updates that have received EASA approval.

Rights and omissions:

• The source text does not articulate rights to appeal, seek exemptions, or to extend compliance beyond the prescribed windows. It does not set out a process for requesting deviations or alternative methods of compliance in the text supplied. The AD is presented as mandatory with fixed compliance dates. The source does not specify sanctions or enforcement mechanisms in the directive text provided; it identifies the Civil Aviation Safety Authority delegate as the issuer (David Villiers). The directive does not enumerate any compensatory provisions for operators who incur costs due to replacement or maintenance-programme amendments.

All duties and flexibilities referenced above come directly from the directive’s requirement and compliance columns, and from the notes that are part of the directive text. Operators should treat the listed actions as mandatory in order to comply with the AD as written.

The source text of the directive does not set out general penalties, fines, or a detailed enforcement regime. The document records the issuing authority as the Civil Aviation Safety Authority, and the directive is signed by David Villiers as delegate, with an effective date of 20 November 2007, but the text supplied contains no express penalty provisions, sanctions, or enforcement procedures. That means the AD itself specifies the safety actions required and the compliance timing, but it does not in its text catalogue how non-compliance will be treated or which enforcement powers will be used. The AD provides a mandatory instruction set: reduce the life limit on records, amend the maintenance programme, and replace straps in defined hour bands within prescribed time windows. Those are obligations imposed on operators in the AD’s operative paragraphs. The absence of express penalties in the text supplied does not itself nullify the obligations; it does mean that the AD does not, within the supplied document, state the regulatory consequences for breach. The AD also references external documents (APEX Aircraft Service Bulletin No. 040102 Revision 1 or later EASA approved revision; EASA AD 2007-0285). Those referenced instruments may carry their own regulatory context or directions. The directive’s explicit compliance deadlines (for example, replacement within 25 hours time in service or one month for certain straps) are mandatory phrasing in the directive. From the source text alone, readers cannot infer the specific enforcement mechanisms CASA would deploy for non-compliance, or whether administrative enforcement, grounding notices, or civil penalties would follow, because none of those mechanisms or penalty scales are described in the supplied AD. Practitioners requiring the legal or enforcement consequences should consult other CASA instruments, statutory powers, or administrative practice that set out sanctions and enforcement procedures; those instruments are not included in the text provided here.

The directive explicitly cross-references two external technical instruments: APEX Aircraft Service Bulletin No. 040102 Revision 1 (or a later EASA approved revision) and EASA AD 2007-0285 (Notes 1 and 2 in the source). The AD mandates amendment of the operator’s maintenance programme to "comply with this new airworthiness limitation", and references the APEX service bulletin as the document that contains the applicable technical instructions. That creates a direct operational interaction between the AD and an operator’s continuing airworthiness documentation: the AD requires the operator’s maintenance programme to incorporate the new component life limitation and to follow the referenced service bulletin’s instructions, where those instructions are EASA-approved. The directive also states its motivation is an EASA AD and a damaged strap discovered with fewer than 4,000 hours, so the CASA directive is explicitly responsive to EASA findings. Beyond these explicit cross-references, the supplied text does not quote or cite national statutes, administrative penalty provisions, or any statutory provision that defines CASA’s regulatory powers. The AD sits as a technical regulatory instrument that compels maintenance-record changes and physical replacements; the mechanism of operation is to change the operator’s maintenance programme and component life limits, which will in practice interact with other regulatory requirements governing airworthiness, maintenance organisation approvals, and record-keeping. The AD’s instruction to amend the operator’s maintenance programme creates an interaction with the operator’s regulatory obligations to maintain up-to-date maintenance programmes, though those broader statutory obligations are not described in the AD text supplied. Where component-level history is not available, the AD prescribes a rule (use the aircraft’s total accumulated hours), which interacts with record-keeping practices by replacing discretion with a prescribed default rule. The AD does not identify or modify rights or duties under other named laws or instruments beyond the referenced EASA AD and APEX service bulletin. Therefore, to understand the full legal interaction , for example enforceability under CASA’s statutory instruments, or how an operator might seek an alternative method of compliance , practitioners must look to CASA’s wider regulatory framework and statutory powers; those are not contained in this directive text.

The directive is titled AD/CAP 10/5 Amendment 1 and the source states "This Amendment becomes effective on 20 November 2007." The background paragraph says that originally a life limit of 4,000 flight hours had been imposed after a previous failure, and that Amendment 1 is issued in response to a new EASA AD prompted by the discovery of a damaged front fuel tank support strap that had accumulated less than 4,000 hours. The amendment therefore mechanically reduces the life limit for the tank support straps to 2,000 hours time in service. The document labels itself "Amdt 1", indicating at least one prior action (the imposition of the 4,000 hour life limit referred to in the background). The supplied text does not provide a prior amendment document, explanatory memorandum, or the original AD text, nor does it list a sequence of earlier amendments beyond noting that a 4,000 hour life limit had previously been imposed. The only date assigned to Amendment 1 is its effective date of 20 November 2007. The AD references EASA AD 2007-0285 as the triggering external action, and recommends compliance with APEX Aircraft Service Bulletin No. 040102 Revision 1, or later EASA approved revisions. The only signatory recorded in the supplied text is David Villiers, Delegate of the Civil Aviation Safety Authority, dated 20 November 2007. No later amendments, superseding ADs, re-issues, or revocations are recorded in the document provided. Therefore, the explicit amendment history contained in the supplied source is limited to: (a) an earlier imposition of a 4,000 hour life limit (background statement), and (b) the present Amendment 1 which lowers the life limit to 2,000 hours and sets replacement requirements and compliance windows, effective 20 November 2007. The directive’s own note that APEX SB revisions that are EASA-approved may be used creates an implicit path for technical updates, but the source does not record any such subsequent revisions or further amendments.

The supplied directive text does not include any litigation history. It contains no references to judicial or administrative decisions, no mentions of appeals, and no record of disputes about the AD’s validity or application. The only external instrument named is EASA AD 2007-0285 and APEX Aircraft Service Bulletin No. 040102 Revision 1 (or later EASA-approved revision), but there is no indication in the document that either of those instruments has been the subject of litigation, within the text provided. Because the AD, as supplied, is a technical airworthiness directive setting mandatory maintenance and record-keeping actions, the absence of litigation references in the text is not unusual: ADs typically set out safety actions rather than case law histories. However, the document itself does not supply any information about whether parties later litigated compliance, enforcement, or interpretation issues arising from this Amendment 1. For users seeking precedent about how courts or tribunals might interpret ambiguous language in this AD, or how CASA enforces compliance and what remedies or penalties have been applied in practice, the directive does not provide that material. Practitioners requiring litigation history must consult external legal databases, case law repositories, or CASA enforcement records; such material lies beyond the supplied text. Within the AD, the operative language is prescriptive and time-bound; the document does not record any formal internal review process, appeals channel, or recorded disputes, so the directive, as supplied, contains no litigation or adjudicative history to summarise.

The source contains several operational and record-keeping traps that may catch operators if not read closely.

1. Life-limit reduction is immediate for records. Requirement 1 requires reducing the life limit from 4,000 to 2,000 hours on the component history card or equivalent record and amending the maintenance programme "before further flight after 20 November 2007" (Compliance 1). That means an aircraft with a strap showing less than 2,000 hours must still have its records and maintenance programme amended prior to the next flight. Failure to update records may create an apparent regulatory non-compliance even if the physical strap is below the new limit.

2. Replacement windows differ by narrow hour bands. Straps that had exceeded 2,000 but were below 2,500 hours on the effective date must be replaced within 100 hours or six months, whichever occurs first. Straps that exceeded 2,500 but were below 4,000 hours must be replaced within 25 hours or one month. It is easy to misapply the faster window to the 2,000-2,500 bracket or vice versa. The AD mandates the shorter window for the higher-hour band.

3. Use aircraft total hours when strap hours unknown. Note 1 prescribes a deterministic method for situations where strap hours are not traceable: the operator must use the aircraft’s total accumulated hours. That can accelerate required replacement if an aircraft has high total hours, and it removes operator discretion to estimate component hours conservatively.

4. The referenced service bulletin must be EASA-approved to count. Requirement 1 refers to APEX Aircraft Service Bulletin No. 040102 Revision 1, "or later EASA approved revision". Operators must ensure any later revision used is EASA-approved. Using a later unrevised or non-EASA-approved SB revision would not meet the specific language in the AD as provided.

5. The AD names a specific part number. The AD applies to front tank support strap part number CAP10-70-08-01; strap variants or modified fittings not carrying that part number may require careful treatment to determine whether the AD applies.

6. The directive’s background explains why the limit was reduced , a damaged strap was discovered with hours below 4,000 , but the AD does not provide fatigue inspection or interim inspection options in the text supplied. The only options provided are the record amendment and replacement within the stated windows, not an alternative inspection regime.

7. The AD text does not set out enforcement measures, appeal routes, or alternative methods of compliance. If an operator wishes to seek a deviation, the directive as supplied does not provide the procedure or authority for that. Practitioners should not infer the availability of an alternative method of compliance from the AD itself.

8. Timing precision. The compliance windows are tied to "time in service" and calendar durations. Operators must track both hours and calendar time to determine the earliest applicable deadline. For example, a strap in the 2,500-4,000 hour band must be replaced within 25 hours or one month, whichever occurs first , meaning replacement could be required in fewer than 25 flying hours if one month expires earlier.

9. Applicability is inclusive of "all serial numbers" for CAP 10B, so retrofit or modified airframes are covered unless expressly excluded; the AD does not list exclusions for special configurations.

10. The AD references EASA AD 2007-0285 (Note 2). Practitioners should verify the content of that EASA AD and the referenced APEX service bulletin for technical instructions and any clarifying material; the AD as provided points to those documents but does not reproduce technical repair or installation procedures.

These are concrete operational pitfalls that arise from the text: misreading the hour bands, failing to update records before flight, reliance on non-EASA-approved service bulletin revisions, and the mandatory default rule where component history is missing.

Follow these concrete steps derived from the directive text.

1. Determine applicability. Confirm the aircraft model is a CAP 10B (all serial numbers are listed as applicable). Confirm the component is front fuel tank support strap part number CAP10-70-08-01.

2. Establish strap accumulated hours. Consult the component history card or equivalent record for the installed strap. If the strap’s hours cannot be established, use the aircraft’s total accumulated hours for the determination, as required by Note 1.

3. Amend records and maintenance programme for straps below 2,000 hours. If the strap has accumulated less than 2,000 hours as of the effective date, reduce the life limit recorded for the strap from 4,000 to 2,000 hours on the component history card or equivalent record, and amend the operator’s maintenance programme to comply with the new airworthiness limitation. Complete these updates before further flight after 20 November 2007, per Compliance 1. Reference APEX Aircraft Service Bulletin No. 040102 Revision 1, or a later EASA-approved revision, when amending the maintenance programme as the AD requires.

4. Replace straps in the 2,000-2,500 hour band. If the strap had exceeded 2,000 hours but was less than 2,500 hours on the effective date, schedule and complete replacement within 100 hours time in service or six months after 20 November 2007, whichever occurs first (Compliance 2).

5. Replace straps in the 2,500-4,000 hour band. If the strap had exceeded 2,500 hours but was less than 4,000 hours on the effective date, schedule and complete replacement within 25 hours time in service or one month after 20 November 2007, whichever occurs first (Compliance 3).

6. Record replacements and update component cards. For each replacement action, record the replacement on the component history card or equivalent, and ensure the life-limit entry reflects the new 2,000 hour safe life for future tracking.

7. Use only EASA-approved service bulletin revisions where the AD specifies. When using APEX Aircraft Service Bulletin No. 040102 Revision 1, confirm whether a later revision has EASA approval. The AD permits "or later EASA approved revision", so only EASA-approved updates satisfy the AD’s wording.

8. Coordinate maintenance scheduling. Because some replacement windows are short (25 hours or one month for the 2,500-4,000 band), operators must integrate replacements into flight scheduling immediately upon determining strap hours to avoid non-compliance.

9. Keep contemporaneous evidence. Maintain dated records showing the life-limit adjustment, maintenance-programme amendment, the method used to determine strap hours (component card or aircraft total hours where applicable), and the replacement work order or release to service. The AD places explicit obligations on component records and the maintenance programme; contemporaneous documentation will demonstrate compliance.

10. Review referenced documents. Obtain and review APEX Aircraft Service Bulletin No. 040102 Revision 1 (or later EASA-approved revision) and EASA AD 2007-0285 to capture any technical instructions, parts specifications, or installation details not reproduced in the AD text.

11. Seek further guidance where uncertain. The AD text does not contain a procedure for alternative methods of compliance or appeals; where a factual or practical difficulty arises (for example supply chain delays for replacement straps), operators should consult CASA or their regulatory contact for guidance on acceptable approaches, because the AD itself does not set out alternative compliance pathways in the supplied text.

These steps mirror the directive’s explicit commands: reduce recorded life limit to 2,000 hours, amend the maintenance programme per the referenced APEX service bulletin, replace straps in the specified hour bands within the stated windows, and use aircraft total hours where strap history is unavailable. Record-keeping and scheduling are the principal operational tasks required for compliance.