AD/CESSNA 206/47 Amdt 3 - Rear Door Emergency Exit

The central concept is the airworthiness directive (AD), a mandatory regulatory instrument issued under the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations 1998 (CASR). An AD compels an aircraft owner or operator to inspect, modify, repair, or replace a part or system to correct an unsafe condition. Non-compliance renders the aircraft unairworthy and invalidates its certificate of airworthiness.

Placard here means a permanently affixed label containing emergency exit instructions. The directive specifies exact wording, font size, colour contrasts, and positioning. The placard must be installed on the forward pillar of the aft cargo door, not on the door itself, to ensure it remains visible even if the door is open.

Latch lever recess is the cavity in the door frame where the latch lever sits. Painting it white (or otherwise highlighting it) is intended to make the lever easier to locate in low-light or smoky emergency conditions.

Cessna Service Bulletin SEB 91-4 is a manufacturer’s service document that improves the cargo door mechanism, likely by adding a spring to the release handle to ensure it returns to the stowed position. The directive treats compliance with this bulletin as an alternative to the new placard. Once the bulletin is accomplished, the placard requirements for groups 1 and 2 are satisfied.

Aircraft Flight Manual (AFM) Limitation Section is the portion of the flight manual that lists mandatory placards, markings, and operating limitations. The directive requires inspection against this for newer serial numbers. The AFM may already contain the correct placard for that specific serial number.

Compliance time is expressed in hours time in service (TIS) or calendar months, whichever occurs first. The 110 hour / 12 month window gives operators a reasonable period to source materials, schedule maintenance, and perform the work. The effective date is 5 August 2011.

Dot-point numbering within the directive distinguishes requirements for each serial number range. Note that the requirements are not cumulative across groups; each group has its own independent obligation.

The directive is an “amendment” (Amdt 3) to an original AD. It supersedes previous amendments 1 and 2. The background section notes that the original AD followed occurrences of difficulty opening cargo doors with flaps down. Amendment 1 provided for a yellow and black placard. Amendment 2 allowed the SEB 91-4 modification as an alternative. Amendment 3 rewords and restructures the directive but only requires new action for groups 2(a) and 3(a) if applicable.

The directive primarily affects owners and operators of any Cessna 206 series aeroplane registered in Australia or operated under an Australian certificate of airworthiness that falls within the listed serial numbers. This includes private owners, flying schools, charter operators, agricultural operators, skydive operators, and any entity conducting aerial work. The Cessna 206 is a popular utility aircraft used for passenger transport, cargo, surveying, and parachute dropping. Because the directive concerns the emergency exit, any aircraft configured with a rear cargo door used as an emergency exit is caught.

Maintenance organizations - both approved maintenance organisations (AMOs) and licensed aircraft maintenance engineers (LAMEs) - must be familiar with the directive to perform the required work, inspect placards, and make logbook entries. They must also ensure they have the correct placard part numbers or the service bulletin kit.

Airworthiness authorities - CASA and its delegates - are the enforcers. They may issue the directive, monitor compliance during airworthiness reviews, and take enforcement action for non-compliance.

Parts suppliers - placard manufacturers and distributors of SEB 91-4 modification kits - will see increased demand during the compliance window.

Insurers may ask for evidence of AD compliance when underwriting hull or liability policies. Non-compliance can void coverage.

Aircraft sellers and buyers - a pre-purchase inspection should check AD compliance. Non-compliance may reduce resale value or delay transfer of registration.

Cessna Aircraft Company - as the type certificate holder, Cessna issued the service bulletin that the directive references. The directive effectively mandates what Cessna recommended.

The directive does not affect operators outside Australia unless the Civil Aviation Safety Authority of another state adopts a similar directive. However, many aviation authorities harmonise with US FAA ADs; this Australian AD may have been triggered by Australian occurrences.

The primary duty is to comply with the directive within the specified compliance time. This duty rests on the holder of the certificate of registration and the person responsible for the continuing airworthiness of the aircraft (the operator). The directive does not name a specific person, but under CASR 42.130, the owner or operator must ensure the aircraft meets all applicable ADs.

For each serial number group, the duty is either:

• Remove old placard, paint lever recess, install new placard (group 1 and 2).
• Or modify door per SEB 91-4 (group 1 and 2).
• Or inspect existing placard against AFM and replace if incorrect (group 3).

The operator has the right to choose between the two options for groups 1 and 2: placard replacement alone or the SEB 91-4 modification. The directive explicitly states that compliance with Cessna Service Bulletin is preferred but not mandatory. This gives the operator flexibility, especially if the aircraft already has the modification.

The operator also has the right to rely on previous compliance. If the work was already done under a previous amendment or under SEB 91-4, no further action is needed. However, the operator must be able to prove that fact, typically via maintenance records or a logbook entry. For group 2, the directive says “unless already accomplished by a previous issue of this Airworthiness Directive” for the painting requirement, and “unless already accomplished” for the modification option.

The operator has the duty to maintain records. Each compliance action must be recorded in the aircraft maintenance log or appropriate record system. The entry should reference the AD number, serial number affected, date of compliance, description of work performed, and signature of the certifying engineer.

Aircraft that do not comply are not airworthy. The operator has a duty not to fly an unairworthy aircraft. Flying in breach is an offence under the Civil Aviation Act with penalties including fines and imprisonment (see section below).

The operator has no right to ignore the directive or seek an extension beyond the compliance time unless CASA grants an alternative means of compliance or a time extension on application. The directive does not provide for automatic extensions.

Non-compliance with an airworthiness directive is a serious regulatory breach. The immediate consequence is that the aircraft is unairworthy. Operating an unairworthy aircraft is an offence under regulation 42.130 of the Civil Aviation Safety Regulations (CASR). The maximum penalty for an individual is 50 penalty units (currently $14,200) and for a body corporate 250 penalty units ($71,000). A court can also impose imprisonment for up to two years for individuals under certain provisions of the Civil Aviation Act.

CASA may also issue a direction to ground the aircraft until the AD is complied with. Failure to comply with such a direction is a separate offence.

Enforcement mechanisms include:

• Airworthiness review - during periodic airworthiness inspections (every 12 or 24 months depending on the aircraft’s operation), the reviewer will check AD compliance. Non-compliance will be flagged, and the aircraft cannot be released to service.
• Incident reports - if an emergency exit fails during an emergency, CASA may investigate and uncover non-compliance, leading to enforcement action.
• Audits - for commercial operators, CASA conducts surveillance and may audit maintenance records.
• Self-reporting - if an operator discovers non-compliance and voluntarily reports, CASA may consider a lower penalty, but the obligation remains to comply promptly.

Civil liability also arises. If non-compliance contributes to an accident causing injury or death, the operator may face civil damages claims for negligence. Insurance may be voided if the aircraft was operated in breach of an AD.

The directive itself does not specify penalties; it is a regulatory instrument. The penalty provisions are in the primary legislation.

Record-keeping is crucial. An operator who cannot prove compliance (e.g., lost logbook entries) is effectively non-compliant. CASA can treat the absence of records as evidence of non-compliance, subject to any rebuttal.

Duration of obligation: The AD continues indefinitely until cancelled, superseded, or incorporated into type design. Even after the compliance date, the requirement to maintain the correct placard remains.

AD/CESSNA 206/47 Amdt 3 sits within a hierarchy of aviation safety law. It is issued under the authority of the Civil Aviation Act 1988 (Cth) and the Civil Aviation Safety Regulations 1998 (CASR), specifically Part 39 of CASR which deals with airworthiness directives. Part 39 empowers CASA to issue ADs to correct unsafe conditions. The directive must be complied with just as if it were a regulation.

The directive interacts with CASR 42.130, which requires the operator to ensure the aircraft meets all applicable ADs. It also interacts with CASR 42.125 concerning continuing airworthiness management. An operator who fails to track ADs may be in breach of those regulations.

The directive cross-references the Aircraft Flight Manual (AFM) Limitation Section. The AFM is itself an approved document under CASR Part 21. The placard requirements must be consistent with the AFM. The AFM for a particular serial number may already contain the correct placard text; the directive forces the operator to check and correct any deviation.

Note that the directive does not override the AFM; it requires the placard to be in accordance with the AFM for serial numbers 20608001 and onwards. For earlier serial numbers, the directive overrides any inconsistent AFM placard (if any) because the directive provides a mandatory placard text.

The directive also interacts with Cessna Service Bulletin SEB 91-4. That bulletin is not a regulation, but the directive makes compliance with it an alternative action. If the bulletin is complied with, the placard requirements are deemed satisfied. This illustrates the interplay between regulatory mandates and manufacturer recommendations.

There is no conflict with other ADs for the Cessna 206. All ADs must be complied with cumulatively.

International harmonisation is relevant. The US FAA issued similar ADs for the Cessna 206. The CASA AD may have been modelled on the FAA AD. Operators flying between Australia and other countries must check the requirements of each state. However, compliance with the CASA AD is sufficient for Australian-operators; they need not also comply with the FAA AD unless specifically adopted by CASA.

The directive is part of a system of continuing airworthiness that includes maintenance program requirements under CASR Part 42 Subpart 42.G. The AD work must be performed by a person authorised under Part 145 or Part 66 of CASR (approved maintenance organisation or licensed engineer). The record must be entered in the technical record system.

The original AD/CESSNA 206/47 was issued before this amendment. The source text does not give the dates of the original AD or of Amdts 1 and 2, but the background section provides context.

Original AD: Issued in response to occurrences in Australia and overseas where cargo doors were difficult to open in an emergency with flaps down. The original AD likely required a placard.

Amendment 1: Provided for a yellow and black placard. This was the initial compliance action. The placard would have been different from the current red/white or yellow/black required by Amdt 3.

Amendment 2: Raised after requests from Australian and UK authorities. Cessna had issued Service Bulletin SEB 91-4 with a service kit to improve the cargo door mechanism. Amdt 2 permitted incorporation of this kit as an alternative to the placard. The background states that “compliance with the Cessna Service Bulletin is preferred but not mandatory.”

Amendment 3 (the current document, dated 1 August 2011, effective 5 August 2011): This amendment rewords and restructures the directive to align with different door mechanisms installed during production of the U206. It introduces three serial number ranges with different placard instructions. It also adds the inspection requirement for later serial numbers. The background explicitly says: “Although extensively reworded at this amendment, only Requirements 2.a and 3.a, if applicable, require new action.” That means aircraft that already complied with Amdt 2 (placard or modification) do not need to do anything new for group 1, but group 2 may need a new placard if the door mechanism is different, and group 3 needs an inspection.

The amendment also notes that 206H and T206H models do not require the revised placards because the SEB 91-4 spring was already incorporated during production.

The amendment was signed by Charles Lenarcic as delegate of CASA. The document is numbered 16/2011.

This amendment history shows a progressive tightening of requirements as the authority learned more about the different door mechanisms. The cost to operators increases with each amendment, but the authority allowed prior compliance to carry forward where possible.

There is no known litigation arising specifically from AD/CESSNA 206/47 Amdt 3. Airworthiness directives are seldom litigated directly; challenges are rare and typically involve administrative review under the Administrative Appeals Tribunal Act 1975 (AAT) or judicial review under the ADJR Act. An aggrieved operator could argue that the directive is unreasonable or that CASA exceeded its power, but such challenges face an uphill battle given the authority’s broad discretion to issue ADs for safety.

The absence of litigation suggests the directive has been accepted by the industry, or that the costs of compliance are low enough relative to the costs of a legal challenge. However, it does not mean the directive is uncontroversial; many ADs are complied with quietly.

There is a possibility of merits review by the AAT, but that would require an application within 28 days of service. The directive was published by CASA and then gazetted. No operator has reportedly sought review.

Civil litigation related to the underlying safety issue (door jamming in an emergency) could involve this AD. If an accident occurs and the aircraft was not compliant, the plaintiff may argue that non-compliance caused or contributed to injuries. Conversely, even if compliant, the operator might still face lawsuit if the door still fails, but the AD compliance would be a strong defence. No such cases are recorded in public databases.

The directive’s existence may be cited in expert reports in any future accident litigation.

Multiple traps await the unwary operator or engineer.

1. Serial number overlaps not obvious. The serial number ranges are: 206-0001 through 206-0275; U206-276 through U206-04649; then U20604650 through U20607020; then 20608001 onwards and T20608001 onwards. Note that the third group begins where the second ends (U20604650), but the first group includes models without the “U” prefix up to 206-0275. The 206H and T206H are excluded from the placard requirement but still included in applicability? The directive says “Models 206 … 206H, and T206H” in the applicability table, but the background says those models do not require revised placards because the spring was incorporated. However, group 3 still requires an inspection for those serial numbers beyond 20608001. So a T206H with serial number above T20608001 still needs to inspect the placard against the AFM. An operator might think no action is needed, but the inspection could still be mandatory if the placard is wrong.

2. Colour specifications. The placard must be “white on a red background or black on a yellow background”. Many aftermarket placards use white on red, which is acceptable. But the background must be red, not maroon or orange. The lettering must be “no less than 3.5mm high” and the words “RESTOW RED LEVER” and “FORCE” must be at least 40% larger than the other lettering. An engineer who installs a placard with uniform lettering is non-compliant.

3. Positioning. The placard must be on the forward pillar of the aft door, centred approximately 150 mm above the window sill line. Not on the door itself, and not elsewhere. The directive includes two images showing the exact layout. If the aircraft has soft trim, the positioning may be tricky. Using the wrong location fails the AD.

4. Painting the latch lever recess. This must be done “to under the soft door trim, or otherwise visibly highlight location of lever”. The word “otherwise” allows alternatives like reflective tape or a coloured insert, but the method must be approved by the engineer and recorded. Simply painting white is the specified method; any alternative must be shown to highlight the lever. A lazy engineer might just paint a small dot, which likely fails.

5. Previous compliance. If the aircraft already has the SEB 91-4 modification, no further action is required for groups 1 and 2, but only if the modification is documented. The directive says “if Cessna Service Bulletin SEB 91-4 has been previously accomplished, no further action is required by this amendment”. But note: this is only for requirements 1 and 2. For requirement 3, even if SEB 91-4 is done, the placard must still be inspected against the AFM. A common mistake might be thinking the entire AD is satisfied.

6. Group 2 placard text is different. The text for group 2 includes an additional step: “ROTATE FORWARD CARGO DOOR HANDLE FULL FORWARD THEN FULL AFT.” Some engineers may apply the group 1 placard to a group 2 aircraft, not realising the difference. The AFM for that serial number may or may not have that step, but the directive overrides the AFM for that group.

7. Record keeping. The compliance time is “after the effective date of this Airworthiness Directive, within 110 hours TIS or 12 months calendar time.” If the operator does the work at 50 hours TIS but does not make a logbook entry until 120 hours, is that compliant? The work must be completed and recorded within the window. A logbook entry should be dated and reference the AD.

8. Lease or charter aircraft. If the aircraft is operated by multiple parties, the responsibility for AD compliance rests with the registered owner or the operator under a continuing airworthiness arrangement. Without clear assignment, both may be liable.

9. The placard “or Rear Cargo Door Emergency Exit” mentioned in requirement 3.a.ii. The directive says “placard or ‘Rear Cargo Door Emergency Exit’ placard as required by the Aircraft Flight Manual.” This suggests the AFM may specify a different but acceptable placard. The operator must get the correct AFM revision.

10. No grace period. The AD is effective 5 August 2011. There is no grandfathering for placards installed under previous amendments unless they meet the new text. For group 1, the old yellow/black placard from Amdt 1 is no longer acceptable; it must be removed.

Compliance involves the following steps.

1. Identify the aircraft serial number. Locate the data plate on the aircraft (usually near the cabin door or inside the baggage compartment). The serial number will have one of the formats listed: e.g., “206-0001” or “U20604650”. If the serial number falls into one of the three ranges, further action is required. If the aircraft is a 206H or T206H with serial number below 20608001, it is still applicable but likely no placard change needed; however, the directive says for group 3 (20608001 and onwards) inspection is required, and for earlier 206H/T206H, the background says the revised placard is not required, but the directive text does not explicitly exclude them from group 1 or 2. Actually, the applicability table lists 206H and T206H. But the serial numbers for 206H likely start above 20608001. Better to check.

2. Check previous AD compliance records. Review aircraft logs to see if a previous amendment of AD/CESSNA 206/47 was complied with, and whether SEB 91-4 was accomplished. If SEB 91-4 is recorded for groups 1 and 2, no further action for that group. For group 3, even if SEB 91-4 is done, still need to inspect the placard.

3. Determine which requirement applies.

   • If serial number is 206-0001 through 206-0275 or U206-276 through U206-04649: Requirement 1 applies.
   • If serial number is U20604650 through U20607020: Requirement 2 applies.
   • If serial number is 20608001 or T20608001 and onwards: Requirement 3 applies.

4. For groups 1 and 2, decide whether to:
   a) Remove old placard, paint latch lever recess white (or highlight), and install new placard with the correct text for the group. The placard must be purchased or fabricated to exact specifications.
   b) Modify the cargo door per SEB 91-4. This may be done by an AMO with the kit. Once done, no placard change needed.

   If option (a) is chosen, ensure the placard is positioned correctly (forward pillar, 150 mm above window sill line). Use white on red or black on yellow background. Lettering as specified.

5. For group 3, inspect the existing placard. Compare it with the Aircraft Flight Manual Limitation Section for that specific serial number. If the placard matches, log that the AD is complied with (inspection only). If not, remove and replace with the correct placard per AFM.

6. Record compliance. In the aircraft maintenance log or appropriate record system, write:

   • AD number: AD/CESSNA 206/47 Amdt 3
   • Date of compliance
   • Description: “Cargo door emergency exit placard installed/checked in accordance with AD/CESSNA 206/47 Amdt 3.” or “Modified cargo door per Cessna SEB 91-4.”
   • Reference to serial number and group.
   • Signature and licence number of certifying engineer.

7. Verify at next inspection. When the aircraft next undergoes an airworthiness review, the reviewer will check the logbook entry and physically inspect the placard. If the entry is missing or incorrect, the reviewer may require rework.

8. Monitor for superseding amendments. The directive may be further amended. Subscribe to CASA’s Airworthiness Bulletin notifications.

Costs: a placard costs a few dollars; painting requires labour; the SEB 91-4 kit costs a few hundred dollars plus installation labour. The compliance time of 110 hours or 12 months allows planning. The main cost is the engineer’s time to read the directive correctly and avoid the gotchas. A mistaken placard may need rework.