AD/CL-600/121 - Stick Pusher Capstan Shaft

The AD rests on a small set of technical and procedural concepts reflected in its requirements and background.

• Stick pusher capstan shaft and stick pusher function. The AD targets failures of the stick pusher capstan shaft that produce “severe degradation of the stick pusher function.” The stick pusher is part of the stall protection system. The AD’s corrective measures are designed to detect degradation (via an amended pre-flight test) and limit exposure to dormant failures (via a repetitive maintenance task introduced as a Certification Maintenance Requirement).

• Aircraft Flight Manual Temporary Revision (AFM TR). The AD mandates inserting a specific AFM temporary revision (TR RJ/178, dated 15 February 2008 or later approved revision) that “introduces a limitation to ensure that the Stall Protection System test is accomplished before the first flight of the day” and requires advising flight crews about the TR’s changes. Functionally, this converts a recommended or manufacturer TR into an operational limitation and flight-crew procedural requirement for affected aircraft.

• Certification Maintenance Requirement (CMR). The AD requires amendment of the Transport Canada-approved maintenance schedule to include Certification Maintenance Requirement C27-35-300-01, as introduced by TR 2A-43 dated 7 May 2008. The CMR task is described in the AD only by reference to that CMR/TR; the AD does not reproduce the task wording or intervals. The AD uses the CMR mechanism to introduce a repetitive maintenance task intended to detect or prevent capstan shaft degradation in service.

• Compliance timing and scope. The AD imposes two time-based windows: a calendar window (within 30 days of the effective date) for AFM and maintenance-schedule amendments, and a flight-hour window (within 500 flight hours after the effective date) for initial compliance for aeroplanes with over 5,000 flight hours at the effective date. The AD designates an effective date of 19 November 2009.

• Inter-jurisdictional cross-reference. The AD explicitly notes a Transport Canada AD (CF-2009-36 dated 2 September 2009) as a related document. It also references specific Bombardier TR documents. The AD therefore operates by importing manufacturer/Type-Certificate-holder materials and foreign regulator ADs into CASA’s mandatory requirements for the specified serial-number subset.

• Applicability by serial number. The AD’s applicability is stated numerically: Bombardier CL-600-2B19 serial numbers 7003 through 7990, 8000 and subsequent. That precise string is the operative scope of affected aeroplanes for CASA purposes under this AD.

These concepts combine operational (crew check), maintenance (CMR incorporation), documentation (AFM TR insertion), and temporal components to mitigate a technically identified failure mode. The AD does not itself reproduce the technical inspection steps or the exact maintenance interval specified in the referenced CMR; it requires their formal incorporation into the operator’s approved documents.

The AD’s actions are directed at operators, maintenance organisations and flight crews of the specified Bombardier CL-600-2B19 aeroplanes in Australia within the stated serial-number range. The text makes clear who must act by requiring amendments to the AFM and to the Transport Canada-approved maintenance schedule, and by specifying flight-crew advice.

• Operators and aircraft owners. The requirement to amend the AFM and to “advise all flight crews on the changes introduced through the AFM TR” places immediate duties on the aircraft operator or owner that holds the AFM and is responsible for operational control or crewing. The AFM is an operator-facing document; inserting TR RJ/178 or a later approved revision into the AFM is an operator action. The AD’s compliance windows (30 days for procedural/document changes; 500 flight hours for initial CMR task for >5,000 flight-hour aeroplanes) allocate a short lead time for operational modifications.

• Maintenance organisations and approved maintenance schedule holders. Requirement 2 directs amendment of the “Transport Canada approved maintenance schedule” to incorporate the inspection requirements of CMR Number C27-35-300-01. For Australian-registered aeroplanes where the maintenance schedule is Transport Canada-approved (likely because the type certificate/maintenance regime originates with Canadair/Bombardier), the holder of that approved maintenance schedule (the operator, continuing airworthiness management organisation or the approved maintenance organisation acting under the operator’s approval) must update the schedule. The AD thereby binds those who prepare and maintain approved maintenance programmes.

• Flight crews. The AFM TR specifically requires that the Stall Protection System test be accomplished “before the first flight of the day” and requires flight-crew advice about the AFM TR changes. That places a recurrent procedural onus on flight crews to perform the stipulated test as part of their first-flight checks on days when the aeroplane operates.

• Aeroplanes meeting the flight-hour trigger. The AD singles out aeroplanes with more than 5,000 flight hours at the effective date for an additional initial action: perform initial compliance with the new CMR task “within 500 flight hours after the effective date” unless previously accomplished. This creates a differentiated timing obligation based on accumulated usage: operators whose aeroplanes exceed that threshold must perform an initial compliance action sooner (within 500 flight hours) than those below the threshold (who will follow the routine CMR cycle once incorporated into the maintenance schedule).

• Design approval/Type Certificate holder and regulator coordination. Although the AD makes no direct command to Bombardier or to Transport Canada within its text, it draws on Bombardier TRs and on Transport Canada AD CF-2009-36. That shows an operational relationship among manufacturer guidance, a foreign regulator’s AD, and CASA’s AD as the instrument binding Australian-registered operations.

• Maintenance planners and scheduling functions within operators. The AD’s calendar and flight-hour compliance timing will affect rostering and maintenance scheduling functions, because the AFM change is immediate (30 days) and the initial CMR compliance for aircraft over 5,000 hours must occur within 500 flight hours. Those are tasks typically executed by technical records staff and maintenance planners.

The AD does not identify any exemptions, alternative means of compliance or appeal routes in its text. It does not state who bears costs; the direction is to perform document amendments, brief crews, and carry out inspections , functions ordinarily paid for by operators or their maintenance providers. The AD does not specify whether the CMR is to be recorded as a mandatory CMR retained in the maintenance schedule forever or for a limited period; operators must incorporate the CMR as described.

The AD imposes clear duties and leaves few explicit rights or procedural protections in the supplied text. The operative obligations are set out as three requirements and associated compliance times. Rights that would normally appear in a fuller regulatory instrument (for example, rights to seek an alternative means of compliance, to appeal, or to defer where operationally necessary) are not present in the text supplied.

Key duties

• AFM amendment and crew advice (Requirement 1). Within 30 days of the effective date, operators must insert Temporary Revision RJ/178 (dated 15 February 2008 or later approved revision) into the Aircraft Flight Manual. The TR “introduces a limitation to ensure that the Stall Protection System test is accomplished before the first flight of the day; and advise all flight crews on the changes introduced through the AFM TR.” Duty-holders therefore must (a) obtain the specified TR or a later approved revision and (b) amend the AFM so that the limitation is in force, and (c) brief or otherwise advise all flight crews of the procedural change.

• Maintenance schedule amendment (Requirement 2). Within 30 days, operators (or maintenance approval holders) must amend the Transport Canada-approved maintenance schedule by incorporating the inspection requirements of CMR Number C27-35-300-01 as introduced by TR 2A-43, dated 7 May 2008. The duty is to incorporate the referenced CMR task into the approved maintenance schedule; the AD does not reproduce the task or intervals, so duty-holders must reference TR 2A-43/CMR C27-35-300-01 to implement the task.

• Initial compliance for high-utilisation aeroplanes (Requirement 3). For aeroplanes with more than 5,000 flight hours at the effective date, the operator must “perform initial compliance with the new CMR task” within 500 flight hours unless already done. That adds a shorter-term, aircraft-specific inspection duty for higher-utilisation aeroplanes.

• Timing and effective date. The AD’s effective date is 19 November 2009. The timing duties (30 days, 500 flight hours) are measured from that date.

Rights and procedures not stated in the AD text

• No AMOC/alternative method in the supplied text. The AD does not, in the text provided, state any mechanism for seeking alternative methods of compliance (AMOCs) or approvals of equivalent measures. It also does not specify procedures for applying for relief, extensions, or temporary alternative arrangements.

• No enforcement or penalty provisions. The AD text supplied does not set out enforcement measures or penalties, nor does it identify an appeal route or review mechanism for parties wishing to contest the AD’s effect on a particular aeroplane.

• Reference to foreign AD and manufacturer TRs. The AD references Transport Canada AD CF-2009-36 and the Bombardier TRs RJ/178 and 2A-43. Rights to rely on manufacturer guidance or other regulators are implied by the references, but the AD makes the referenced documents mandatory through incorporation by reference; it does not itself create sampling rights or carve-outs.

• Documentation obligations implicit in the AFM and maintenance schedule changes. By requiring AFM and maintenance-schedule amendments, the AD imposes familiar documentary and record-keeping obligations: the AFM must contain the TR-located limitation; the approved maintenance schedule must include the CMR. The AD does not expressly say how incorporation is to be documented, but the nature of AFM and approved-schedule amendments implies record updates and audit traces.

In summary, the AD prescribes concrete, short-term duties on operators, maintenance schedule holders and flight crews for the affected serial-numbered aeroplanes, but does not record procedural rights or appeal mechanisms in the supplied text. Any procedural rights or AMOC routes would need to be sought in CASA’s broader regulatory framework or in the full AD documentation beyond the excerpt supplied.

The supplied AD text does not state any penalties, sanctions, or enforcement procedures. The document sets mandatory requirements, compliance timelines and an effective date, but it does not itself specify the legal consequences of non-compliance, inspection regimes, or enforcement powers.

What the AD does state, relevant to enforcement context

• Effective date and compliance timings. The AD states: “This Airworthiness Directive becomes effective on 19 November 2009.” It sets compliance timing for Requirements 1 and 2 as “Within 30 days of the effective date of this AD” and for Requirement 3 as “Within 500 flight hours after the effective date of this AD unless previously accomplished.” Those temporal specifications are the compliance thresholds that a regulator would typically use as the basis for inspection and enforcement action, even though the AD excerpt does not itself set out the enforcement process.

• Issuing authority. The AD is signed by “David Villiers, Delegate of the Civil Aviation Safety Authority” and dated 28 September 2009. That indicates the AD is an instrument issued by CASA acting through its delegate. The AD’s authority to require the specified changes is conveyed by its issuing office and signature, but the AD excerpt does not reproduce the enabling statutory provisions (for example, the Civil Aviation Act or regulations) or CASA’s enforcement powers. The absence of those enabling or penalty provisions in the supplied text means the AD should be read alongside applicable aviation safety legislation and CASA enforcement procedures to understand the full enforcement consequences.

What is not in the AD text

• No penalty schedule, fines, or infringement notices are listed in the AD excerpt provided. The AD does not state whether non-compliance will result in grounding, civil penalties, certificate suspension, or other administrative or criminal sanctions. It also does not state whether temporary operations might be authorised while compliance is being achieved.

• No inspection or audit procedure is set out. The AD does not indicate how CASA will verify compliance (for example, by ramp inspections, document checks, or surveillance audits) or the frequency of such checks.

• No alternative means of compliance (AMOC) or approval-by-exception pathways. The AD does not include any express procedure to obtain CASA approval for alternative compliance methods or deviations from the TR/CMR requirements.

Practical consequence for users of the AD

• Operators and maintenance organisations should treat the AD’s requirements and timelines as mandatory for the listed aircraft. Although this excerpt lacks an explicit penalty clause, ADs are normative regulatory instruments in aviation safety practice; compliance with the stated actions and timings is necessary to ensure the aircraft meets the operator’s AFM and approved maintenance schedule obligations. For any questions about enforcement, penalties or AMOC processes, affected parties would need to consult CASA’s wider regulatory instruments or contact CASA directly.

Because the AD excerpt does not provide enforcement details, affected parties must look to the full AD publication, the Civil Aviation safety legislation and CASA guidance materials for the procedures, potential sanctions and the process to seek relief or an AMOC.

The AD cross-references and imports material from other regulatory and manufacturer sources rather than restating those sources. Within the supplied text the explicit interactions are limited to the references to Transport Canada and to Bombardier/Bombardier TRs. The AD itself does not reproduce domestic enabling statutes or regulatory provisions in the excerpt provided.

Direct textual interactions recorded in the AD

• Reference to Transport Canada AD. The AD contains the note: “Note: Transport Canada AD CF-2009-36 dated 2 September 2009 refers.” That indicates a parallel or prior AD by the Canadian regulator that addresses the same technical issue. The CASA AD therefore interacts with foreign regulatory action by recognising and incorporating similar remedial steps. The AD does not reproduce Transport Canada’s text; it relies on a cross-reference.

• Incorporation by reference of manufacturer TRs and a CMR. The AD requires insertion of AFM Temporary Revision RJ/178, dated 15 February 2008 or later approved revision, and incorporation of CMR Number C27-35-300-01 as introduced by Temporary Revision 2A-43 dated 7 May 2008 of the Canadair Regional Jet Maintenance Requirements Manual. That creates an operational interaction between CASA’s AD and Bombardier’s documentation: CASA’s AD makes compliance with specific manufacturer-issued TRs and CMRs a mandated element of Australian operations for the listed aircraft.

Implications for approval and maintenance frameworks

• Interaction with Transport Canada-approved maintenance schedules. The AD requires amendment of the “Transport Canada approved maintenance schedule,” which indicates a cross-jurisdictional link in maintenance approvals and documentation. Australian operators who rely on a Transport Canada-approved schedule, or whose maintenance is governed by arrangements referencing Transport Canada documents, must incorporate the CMR into that approved schedule. The AD thereby binds operators to modify foreign-regulator-approved maintenance schedules in line with CASA’s instruction.

• Documentation hierarchy. By referencing AFM TRs and CMRs, the AD situates CASA’s requirement within the established documentation hierarchy used in continued airworthiness: AFM limitations and certified maintenance requirements. Operators must therefore align AFM contents and approved maintenance programmes with the referenced TRs. Because the AD references “or later approved revision” for the AFM TR, it also allows for incorporation of updated TRs that are later approved, indicating a dynamic interaction with manufacturer updates.

What the AD does not state about interaction with other laws

• No explicit mention of the Civil Aviation Act, Civil Aviation Safety Regulations, or Civil Aviation Orders. The AD excerpt does not reproduce the statutory basis for the AD or spell out CASA’s enabling powers and enforcement remedies. Those interactions exist but are not set out in the supplied text; affected parties should consult CASA’s broader regulatory framework to understand the legal basis and how the AD fits into broader regulatory obligations.

• No stated effect on contractual terms, insurance or operating certificates. The AD does not explicitly address whether operators must notify insurers, lessors, or other contractual counterparties. Practitioners should infer that AFM and maintenance-schedule changes will be relevant to continued airworthiness obligations, but the AD itself does not specify contractual or insurance consequences.

• No harmonisation clause. The AD does not expressly state whether compliance with Transport Canada AD CF-2009-36 or with the Bombardier TRs will be treated as sufficient for CASA compliance. It references them, and it mandates specific Bombardier TRs, but it does not include harmonisation language beyond those references.

Overall, the AD operates by importing manufacturer TR material and a foreign regulator AD into CASA’s enforcement sphere for the listed aircraft. Operators and maintenance organisations must therefore treat the referenced TRs and CMR as mandatory elements of the AFM and the approved maintenance schedule in order to comply with CASA’s AD, and must consult CASA and the referenced documents for the detailed technical content and intervals that the AD does not itself reproduce.

The supplied AD excerpt provides limited amendment history information. What it does record is the signature and dates for the AD itself and the dates of the manufacturer Temporary Revisions that the AD requires to be incorporated.

Recorded dates and revisions

• AD issue and effective dates. The AD is dated 28 September 2009 (signed by David Villiers, Delegate of CASA) and the text records: “This Airworthiness Directive becomes effective on 19 November 2009.” Those are the core dates in the AD lifecycle as documented in the excerpt: the date of issue (28 September 2009) and the effective date (19 November 2009).

• Manufacturer TR dates. The AFM insertion requirement specifies Temporary Revision RJ/178 dated 15 February 2008 (or a later approved revision). The maintenance CMR requirement specifies Temporary Revision 2A-43 dated 7 May 2008, which introduced Certification Maintenance Requirement Number C27-35-300-01. The AD therefore gives explicit precedence to specific TR versions and allows later approved revisions for the AFM TR.

• Reference to Transport Canada AD date. The AD includes the note: “Transport Canada AD CF-2009-36 dated 2 September 2009 refers.” That indicates a related foreign-regulator action occurred on 2 September 2009. The CASA AD as issued on 28 September 2009 therefore follows the Transport Canada AD in time.

What the AD excerpt does not record

• No record of prior CASA ADs on the same subject. The supplied excerpt does not state whether CASA previously issued earlier ADs addressing the same stick pusher capstan shaft issue. It does not include versioning history or amendments to the CASA AD itself.

• No record of later amendments or revocations. The excerpt does not indicate whether the AD has been amended, superseded, extended, or revoked after its effective date. The language “or later approved revision” for TR RJ/178 allows operators to use later approved TR revisions for the AFM requirement without the AD itself being formally amended to list the later TR, but the AD excerpt does not show any subsequent CASA action.

• No list of earlier Bombardier TRs. The AD identifies RJ/178 and 2A-43 as the TRs of interest, but does not list any predecessor TRs or later related service bulletins. The CMR is referenced only by its number and the TR that introduced it.

Implication for record-keeping and audit

• Operators must document the insertion of the specified TR into the AFM and the incorporation of the CMR into the Transport Canada-approved maintenance schedule; those records will serve as the primary evidence of compliance with the AD at the date specified. Because the AD refers to specific TR dates, operators should retain the TR documents with their revision dates to show that they used an approved TR version.

• Because the AD allows incorporation of “later approved revision” for the AFM TR, operators adopting a later TR should keep evidence of the revision being an “approved revision” at the time of incorporation.

Where to look for further amendment history

• The AD excerpt itself is limited. For a full amendment history, affected parties should consult CASA’s official AD repository or the full AD publication for any later revisions, supersedures, or cancellation notices, and consult Transport Canada and Bombardier service-document repositories for the evolution of the TRs and the CMR. The AD excerpt does not supply that later-history information.

The supplied AD contains no litigation history. It does not cite any court decisions, references to judicial review, or prior case law. The AD is technical in nature and is presented as an administrative safety measure; the excerpt does not include or reference any legal proceedings brought in relation to the AD, the Bombardier TRs, or the referenced Transport Canada AD.

What the AD does provide that is relevant to potential litigation

• Factual basis and rationale. The AD records a technical factual rationale: “There have been several Stick Pusher Capstan Shaft failures causing severe degradation of the stick pusher function.” That factual statement is the technical underpinning for the AD and would be the kind of matter considered in any challenge to an AD where factual sufficiency or reasonableness was in issue. The AD links the remedy to the risk: it revises the first-flight-of-day check to detect degradation and introduces a repetitive maintenance task to limit exposure to dormant failure.

• Certainty of dates and documents. The AD sets out specific TRs and a specific CMR number and dates. For litigation about compliance timing or scope, those specific references are important evidentiary anchors: a court or review body would consider whether the operator complied with the specified TR and CMR within the given compliance windows.

• Absence of procedural description. The AD excerpt does not disclose whether CASA provided an opportunity for consultation, industry comment or otherwise prior to the AD’s issue, nor does it describe an administrative process for exemptions or AMOCs. If litigation were raised on procedural grounds (for example, lack of consultation, or denial of a requested AMOC), the relevant procedural material would need to be found in the broader CASA AD record and the enabling statute/regulations, not in the AD excerpt itself.

No recorded cases named in the AD

• The AD does not name any legal authorities or cases. It references Transport Canada AD CF-2009-36 and Bombardier TRs but not judicial decisions. As required by the instructions for this analysis, no cases beyond those cited in the AD can be named.

Practical implication for counsel and compliance officers

• Because the AD excerpt contains no litigation history, practitioners seeking information on any legal challenges, enforcement actions or precedents must consult agency records, court databases and CASA publications beyond the text supplied here. The AD’s precise record of TR and CMR references and the effective date will be the starting points for any audit or dispute over compliance.

The AD contains several features that may cause operational or compliance surprises if read hastily. The following items are drawn only from the text of the AD itself and do not invoke external material.

Applicability phrasing and potential serial-number gap

• The AD’s applicability reads exactly: “Bombardier CL-600-2B19, serial numbers 7003 through 7990, 8000 and subsequent.” That phrasing explicitly lists 7003-7990, and then 8000 and subsequent. The sequence appears to omit serial numbers in the 7991-7999 range. The AD does not explain the omission. Practitioners should note that the applicability is the wording given; whether the omission reflects a deliberate exclusion (for example, because those serial numbers do not exist or are covered by another AD) or a drafting oddity is not explained in the AD text. Operators should verify applicability against their aircraft serial numbers rather than assume continuous ranges.

Reference to “Transport Canada approved maintenance schedule”

• Requirement 2 prescribes amendment of the “Transport Canada approved maintenance schedule” to include CMR C27-35-300-01 as introduced by TR 2A-43 dated 7 May 2008. Australian operators must be alert that the AD requires amendment of a foreign-regulator-approved maintenance schedule. If an Australian operator’s maintenance schedule is not a Transport Canada-approved schedule, or if maintenance approvals differ across jurisdictions, the operator will need to ensure that the equivalent approved maintenance programme used domestically is updated to incorporate the CMR so as to satisfy the AD. The AD does not explain how to proceed where a Transport Canada-approved schedule is not the operative maintenance authority for an Australian-registered aeroplane.

Use of “or later approved revision” for AFM TR but not for CMR TR

• The AFM TR insertion language permits “TR RJ/178, dated 15 February 2008 or later approved revision.” For the CMR the AD specifies incorporation “as introduced by Temporary Revision (TR) 2A-43, dated 7 May 2008.” The CMR wording does not include “or later approved revision” language in the provided excerpt. That difference may affect whether a later Bombardier revision to the CMR is automatically acceptable under the AD language; operators should check whether later revisions to TR 2A-43 or the CMR are endorsed by CASA or require an express amendment to the AD.

CMR content and intervals not reproduced

• The AD requires incorporation of CMR Number C27-35-300-01 but does not reproduce the task wording, inspection steps or intervals. Operators must obtain TR 2A-43 and the CMR text to know what inspection is required and how often. The absence of the CMR text in the AD excerpt means compliance cannot be certified from the AD alone; operators must source and retain the CMR/TR documents themselves.

Short compliance windows and flight-hour trigger

• Requirements 1 and 2 must be accomplished “Within 30 days of the effective date.” The effective date is 19 November 2009. That imposes a short calendar window for AFM and maintenance-schedule changes. For aircraft with more than 5,000 flight hours at the effective date, initial compliance with the CMR must be performed “Within 500 flight hours after the effective date.” Operators with heavy utilisation profiles should map flight-hour counting immediately to determine when the 500-flight-hour window expires. The AD does not specify whether the 500-flight-hour window may be measured from hours-in-service or cycles; operators must rely on the CMR/TR and CASA guidance to clarify the measurement basis.

Mandate to “advise all flight crews”

• The AFM TR requires operators to “advise all flight crews on the changes introduced through the AFM TR.” That is operationally simple in principle but logistically significant in larger fleets or where multiple crew pools operate the aeroplane. The AD does not specify the method or evidence of advising; operators should plan for signed briefings or training records to evidence compliance.

No AMOC or relief language in the excerpt

• The AD text does not provide a route for seeking an alternative method of compliance. If operators believe a different procedural or maintenance approach would be equally safe, the AD excerpt does not indicate how to seek CASA approval for an alternative. Operators should consult CASA’s wider AD protocols to find the AMOC pathway.

No enforcement detail in the AD excerpt

• The AD does not set out enforcement powers, penalties or audit mechanisms. Operators should not assume lack of enforcement; rather, they should anticipate that CASA’s broader enforcement framework applies. The AD excerpt itself does not say so.

Background facts are stated without technical detail

• The AD states that “There have been several Stick Pusher Capstan Shaft failures causing severe degradation of the stick pusher function.” The AD does not provide failure rates, accident details, or the precise failure mechanisms. That means affected parties must obtain further technical materials (for example, the Bombardier TRs or Transport Canada AD) to understand the engineering basis and to plan maintenance work accordingly.

In sum, the potential surprises arise from the exact framing of applicability, the need to fetch external documents (TR RJ/178 and TR 2A-43/CMR C27-35-300-01) to implement the AD, short compliance windows tied to an effective date, and the absence of procedural AMOC/penalty wording in the excerpt. These are practical points that will be decisive when drafting compliance checklists and audit trails.

The AD sets out three discrete compliance steps and associated timeframes. This section restates those steps in operational terms and flags the documents and evidentiary items operators should secure and record in order to demonstrate compliance.

Step 1 , AFM amendment and crew advice (Requirement 1)

• Obtain Temporary Revision RJ/178 dated 15 February 2008, or a later approved revision. The AD expressly allows the later approved revision for the AFM TR insertion: the wording is “TR RJ/178, dated 15 February 2008 or later approved revision.” Keep a copy of the specific TR and note its revision date and approval status.
• Insert the TR into the Aircraft Flight Manual so that the AFM carries the limitation “to ensure that the Stall Protection System test is accomplished before the first flight of the day.” Make the AFM amendment in accordance with your approved AFM amendment procedures and record the AFM revision/control log entry.
• Advise all flight crews of the AFM TR changes. Evidence could include signed crew briefings, training session records, email notices with read receipts and any checklist revisions that incorporate the first-flight-of-day Stall Protection System test. The AD requires the advice; operators should document the method and personnel briefed.

Timing for Step 1

• The AD requires Steps 1 and 2 “Within 30 days of the effective date of this AD.” The effective date is “19 November 2009.” Therefore, insert the AFM TR and brief crews by 19 December 2009 unless an earlier effective date applies to your operations via another route.

Step 2 , Maintenance schedule amendment (Requirement 2)

• Obtain Temporary Revision 2A-43 dated 7 May 2008 to the Canadair Regional Jet Maintenance Requirements Manual, Part 2, Appendix A, which introduces Certification Maintenance Requirement C27-35-300-01. Secure the exact TR text and the CMR wording and intervals.
• Amend the Transport Canada-approved maintenance schedule to incorporate the inspection requirements of CMR C27-35-300-01. Ensure that the amendment is done in accordance with the process used for changes to the approved maintenance schedule. If your organisation holds the Transport Canada approval, annotate the approved schedule; if another entity holds that approval, coordinate promptly to effect the approved-schedule change.
• Record the maintenance-schedule amendment in the operator’s continuing airworthiness records and technical logs, and allocate work orders for the repetitive maintenance task as required by the CMR.

Timing for Step 2

• The maintenance-schedule amendment must be completed “Within 30 days of the effective date.” Operators should map internal approval cycles and ensure that the schedule change is processed and documented within that window.

Step 3 , Initial compliance for high-utilisation aeroplanes (Requirement 3)

• Identify aeroplanes that had more than 5,000 flight hours at the AD effective date. The AD states: “For aeroplanes with more than 5,000 flight hours at the effective date of this AD - perform initial compliance with the new CMR task.”
• For those aeroplanes, perform the initial CMR inspection “Within 500 flight hours after the effective date of this AD unless previously accomplished.” Determine how the operator counts flight hours (e.g., Hobbs or airframe hours) and apply the same counting convention to measure the 500-flight-hour window.
• Document the initial CMR inspection work packages, findings and any remedial action taken in continuing airworthiness records. If the initial inspection reveals findings requiring corrective action, record the corrective tasks against the airframe and ensure subsequent maintenance scheduling reflects the CMR’s recurring interval.

Implementation practicalities and record-keeping

• Source the referenced documents. The AD requires incorporation of TR RJ/178 (AFM) and TR 2A-43/CMR C27-35-300-01 (maintenance). These documents are not reproduced in the AD excerpt; operators must obtain them from Bombardier or the relevant document repositories and retain them as compliance evidence.
• Evidence of compliance. For AFM amendment: AFM revision pages with control logs, crew briefing sign-in sheets, revised checklists and procedural notes. For maintenance schedule amendment: revised approved maintenance schedule showing CMR C27-35-300-01, approval records (if needed), and scheduling entries. For inspections: maintenance release documentation, defect rectification records and sign-off by appropriately authorised maintenance personnel.
• Coordinate with maintenance approval holder(s). If the operator’s maintenance schedule is Transport Canada-approved by another organisation or if maintenance is contracted, coordinate immediately to ensure the maintenance-schedule change is made and the initial CMR inspection is scheduled within the 500-flight-hour window.
• Plan for operational effects. The AFM limitation requires the Stall Protection System test before the first flight of the day. Incorporate the test into first-flight checks and crewing schedules; plan for any additional ground time required and ensure crews are trained in the exact test procedure as specified by TR RJ/178.

If questions arise about applicability or interpretation

• The AD excerpt does not provide an AMOC route or operational relief language. Where an operator believes alternative procedures are technically appropriate, consult CASA’s AD guidance and communication channels to seek clarification or to request an alternative means of compliance in accordance with CASA’s procedures.

Checklist summary

• By 30 days after 19 November 2009: insert AFM TR RJ/178 (or later approved revision) and advise all flight crews; amend the Transport Canada-approved maintenance schedule to include CMR C27-35-300-01 as introduced by TR 2A-43.
• For aeroplanes with >5,000 flight hours on the effective date: perform initial compliance with the CMR within 500 flight hours after 19 November 2009 unless already done.
• Document every step: AFM revision logs, crew briefings, approved schedule amendments, inspection records, corrective actions and maintenance releases.

Following the above steps will implement the AD’s stated requirements in the operational and maintenance records that auditors or CASA inspectors will typically review.

Note: the AD excerpt contains minimal amendment-history content beyond the initial issuance and referenced manufacturer TR dates. This section restates those items and the limited amendment-related language in the AD for clarity.

Dates recorded in the AD excerpt

• Bombardier Temporary Revisions cited:
  • TR RJ/178, dated 15 February 2008 (or later approved revision) , to be inserted into the AFM (Requirement 1).
  • TR 2A-43, dated 7 May 2008 , which introduced Certification Maintenance Requirement C27-35-300-01 (Requirement 2).
• Transport Canada AD referenced:
  • Transport Canada AD CF-2009-36 dated 2 September 2009 is noted in the AD as a related document.
• CASA AD dates:
  • The AD is signed by David Villiers, Delegate of the Civil Aviation Safety Authority, dated 28 September 2009.
  • The AD states: “This Airworthiness Directive becomes effective on 19 November 2009.”

Language allowing later approved revisions

• The AFM requirement expressly permits insertion of “TR RJ/178, dated 15 February 2008 or later approved revision.” That language allows adoption of later-approved TR versions for the AFM amendment without the need for CASA to issue a new AD to capture later TR versions. The CMR incorporation language does not use identical permissive phrasing for later revisions in the excerpt; it requires incorporation “as introduced by Temporary Revision (TR) 2A-43, dated 7 May 2008.” Whether later CMR revisions are acceptable under the AD would require checking whether CASA has issued further guidance or an amended AD.

What the excerpt does not contain on amendment history

• No record of amendments to the CASA AD itself after 28 September 2009 or after the effective date is present in the excerpt.
• No list of superseding or superseded ADs is provided in the excerpt.
• No record of whether the AD was later rescinded, amended, or incorporated into a broader AD series is provided.

Implication for document control

• The AD’s explicit references to TRs and the effective date mean operators should treat the AFM TR and CMR TR in effect at the time as the operative documents unless and until CASA issues a later amendment. Because the AFM TR allowance includes “or later approved revision,” operators may adopt later approved AFM TR revisions but should retain documentary evidence of the revision used.

For a full amendment history beyond what is shown here, consult CASA’s official AD repository and Bombardier’s service document archives to trace any subsequent CASA actions, revised TRs, or related ADs that post-date the excerpt supplied.

The AD excerpt contains no litigation history or reference to court proceedings. It does not identify any litigation that challenges the AD, any enforcement actions brought as a result of non-compliance, or any judicial decisions interpreting the AD’s requirements. The text lists technical and administrative facts only: the TR and CMR references, the compliance windows, the effective date, and the background on the safety issue.

Practical note for those seeking litigation materials

• Absence of litigation history in the AD excerpt does not mean there has been none; it simply means the AD text supplied does not report any. To determine whether any litigation, enforcement or dispute has arisen from this AD, interested parties must review CASA’s enforcement records, tribunal and court records, and the full public docket for the AD (including any AMOC filings, notices of violation, or administrative appeals).

Where litigation might arise, conceptually

• Litigable points in AD contexts more generally tend to include: challenges about whether the regulator had sufficient factual basis for an AD, claims that the AD exceeds the regulator’s statutory power, disputes about the AD’s applicability to a particular aircraft due to serial-number interpretation, disagreements about measurement of flight hours for compliance windows, and claims about enforcement actions following alleged non-compliance. The AD excerpt does not supply any litigation outcomes or precedent on such points here.

Counsel and practitioners should treat the AD’s exact wording and dated references as critical evidence in any enforcement or judicial scrutiny. If litigation is a concern, obtain the full AD publication, CASA correspondence, and the Bombardier TRs and Transport Canada AD referenced in the excerpt to prepare the factual and documentary record.

This second “Gotchas” section reiterates and expands on practical traps that arise from the precise words of the AD. These items derive only from the AD text; they are not extrapolations based on external regulation.

1. Serial-number wording and possible omission

• Applicability: “Bombardier CL-600-2B19, serial numbers 7003 through 7990, 8000 and subsequent.” The explicit skipping of 7991-7999 is unusual in a serial-number range. Operators must check whether their serial number falls within the stated range; do not assume continuity. The AD does not explain the omission; verify against manufacturer records and CASA for correct applicability.

2. AFM TR permissive language vs CMR specificity

• AFM TR language allows “or later approved revision” for RJ/178; the CMR incorporation is tied to TR 2A-43 dated 7 May 2008 without the same permissive clause in the excerpt. If a later revision to TR 2A-43 or the CMR is published, it is not self-evident from the AD whether that later revision is acceptable without further CASA approval. Operators should clarify with CASA whether later CMR revisions are acceptable or whether a formal AD amendment is necessary.

3. Reliance on external documents

• The AD requires incorporation of documents (TR RJ/178 and TR 2A-43/CMR C27-35-300-01) that are not included in the AD text. You must obtain these documents to implement the AFM and maintenance-schedule changes. The AD’s wording is not a substitute for the TRs’ technical content.

4. Short compliance windows

• 30 days for AFM and maintenance-schedule changes; 500 flight hours for initial CMR for >5,000-hour aeroplanes. These short windows compress the time available for internal approvals, for sourcing TRs, for briefings and for arranging maintenance slots , especially in busy fleet operations.

5. “Advise all flight crews” is open-ended

• The AD requires advising “all flight crews” of the AFM TR changes. It does not prescribe the form of advice or the documentation required to prove that advising occurred. Use conservative evidence (signed briefings, training logs, checklist updates).

6. Measurement of the 500 flight hours

• The AD says “Within 500 flight hours after the effective date.” The AD does not define how to measure these hours (airframe hours, Hobbs, cycles). Confirm the operator’s record-keeping convention and apply it consistently. Keep contemporaneous records to show when the 500 flight hours elapsed.

7. Transport Canada maintenance schedule reference

• The AD requires amendment of the “Transport Canada approved maintenance schedule.” If your approved maintenance schedule is held under a different authority, you must ensure the equivalent approved schedule used for your aircraft is updated to include the CMR; coordinate with the approval holder to ensure the approved-schedule change is effected.

8. No AMOC or enforcement detail in the excerpt

• If you seek an alternative compliance method or a grace period for operational reasons, the AD excerpt does not provide the pathway. Consult CASA’s broader AD and AMOC procedures promptly.

9. Background statement without failure detail

• The AD refers to “several Stick Pusher Capstan Shaft failures” but supplies no technical failure report or recommended corrective steps beyond the AFM TR and CMR incorporation. Obtain the TRs and Transport Canada AD to understand the precise inspection and test steps and the failure modes being addressed.

10. Record-keeping is critical

• Because the AD relies on external TRs and CMRs, operators must maintain the specific TR documents, AFM revision logs, maintenance schedule approval changes, inspection records and crew-briefing evidence to prove compliance during oversight or audit.

These “gotchas” stem from the AD’s concise format and cross-referencing approach. They are procedural and documentary in nature; addressing them requires careful documentary control, prompt coordination with maintenance approval holders, and direct liaison with CASA where clarification or approval of alternative means is considered necessary.

This final compliance-focused section summarises actions, allocates responsibilities and lists documents that should be created and retained to demonstrate compliance with the AD as written.

Immediate actions (within 30 days of the effective date 19 November 2009)

• Obtain TR RJ/178 (15 February 2008) or a later approved revision for the AFM change.
• Insert the TR into the AFM as a limitation requiring the Stall Protection System test be accomplished “before the first flight of the day.”
• Prepare and execute a flight-crew briefing program. Evidence to retain: briefing attendance sheets signed by each crew member, training minutes, emails with read receipts, or checklist updates reflecting the new first-flight-of-day test.
• Obtain TR 2A-43 (7 May 2008) and the text of CMR C27-35-300-01.
• Amend the Transport Canada-approved maintenance schedule to include the CMR task. Evidence to retain: revised approved maintenance schedule, approval record for the schedule change (if issued), and a revision control page showing incorporation of the CMR.

Actions for aeroplanes with >5,000 flight hours at effective date (within 500 flight hours)

• Identify airframes with more than 5,000 flight hours on 19 November 2009.
• Schedule and perform the initial CMR inspection within 500 flight hours after 19 November 2009, unless the task has already been accomplished. Evidence: work orders, maintenance release, NDT or inspection reports, and corrective-action records as applicable.

Ongoing actions

• Ensure that the CMR task is entered into the maintenance planning system at the correct recurring interval, as specified in CMR C27-35-300-01, so that subsequent repetitions of the maintenance task occur on schedule.
• Integrate the Stall Protection System first-flight-of-day test into normal operational checklists and flight crew standard operating procedures. Record any anomalies detected during the test and remedial actions taken.
• Retain copies of the specific TR versions used for AFM and CMR implementation, including the TR revision dates and approval records.

Record-keeping checklist (minimum)

• Copy of TR RJ/178 used and AFM revision/control log entry showing insertion date.
• Crew briefing records demonstrating that all flight crews were advised.
• Copy of TR 2A-43 and the text of CMR C27-35-300-01 used to amend the maintenance schedule.
• Revised Transport Canada-approved maintenance schedule showing incorporation of the CMR (or equivalent documentation if the operator’s maintenance schedule is authorised under another approval).
• Inspection records for the initial CMR task and subsequent repetitions.
• Maintenance release forms or certificates showing sign-off by authorised maintenance personnel.
• Planning records demonstrating that the initial CMR inspection for >5,000-hour aeroplanes was scheduled and performed within the 500-flight-hour window.

Coordination and queries

• If you operate under a maintenance approval held by another entity (for example where Transport Canada approval is held by the lessor or an overseas operator), coordinate urgently to ensure the approved maintenance schedule amendment is performed.
• If there is any uncertainty about whether a later revision of the CMR TR is acceptable, or about applicability to a specific serial number (for example where serial numbers fall in the 7991-7999 range), consult CASA and obtain written clarification.
• For questions about how flight hours are to be counted for the 500-flight-hour window, confirm your operator’s flight-hour accounting method and document the basis for your counting.

Audit and inspection readiness

• Prepare a compliance binder that contains the TRs, the AFM revision pages, crew-briefing evidence, the revised approved maintenance schedule, initial-inspection records and a summary compliance timeline tied to the AD effective date. This binder will expedite reviews by CASA or auditors.

Final note

• The AD’s requirements depend on external manufacturer TRs and a foreign-regulator AD for technical content. Compliance requires obtaining and faithfully implementing those documents and documenting each step taken within the timeframes the AD prescribes. If alternative solutions are sought, engage CASA early to determine the acceptability of alternative methods of compliance under CASA procedures.