AD/DHC-8/134 - Fuel System Safety

The Directive rests on a short set of technical and administrative concepts that determine what the instrument requires and why. Critical Design Configuration Control Limitations (CDCCL) are central: the directive requires their incorporation into Part 2 “Airworthiness Limitations List” of the Maintenance Program Manuals for the affected DHC-8 models (Requirement, a). The instrument does not provide a definition of CDCCL within its text; it treats CDCCL as items introduced by the Temporary Revisions to the AWL that must be managed and controlled by operators (Requirement, opening sentence). Part 2 AWL TRs are the means by which the particular CDCCL items are specified: TR AWL-98 (DHC-8-100 series), TR AWL 2-35 (DHC-8-200 series) and TR AWL 3-103 (DHC-8-300 series) are explicitly named and cross-referenced to specific Maintenance Program Manual pages (Requirement, a(i)-(iii)).

Maintenance Program Manuals and their Part 2 “Airworthiness Limitations List” are the instrument’s administrative vehicle. The Directive requires each operator to amend their copies of the applicable Maintenance Program Manual to incorporate the CDCCL items introduced in those TRs (Requirement, a). In addition, operators must amend any of their DHC-8 related procedures or documentation to highlight both the existence of those CDCCL items and the necessary requirements to maintain the design features of those items (Requirement, b).

The safety standard that precipitated the Directive is identified in the Background: Bombardier completed a system safety review of the aircraft fuel system against fuel tank safety standards introduced in Chapter 525 of the Airworthiness Manual through Notice of Proposed Amendment (NPA) 2002-043 (Background). Non-compliances were assessed using Transport Canada Policy Letter No. 525-001 to determine whether mandatory corrective action was required (Background). The Background frames the CDCCL introduction as necessary “to preserve critical fuel tank system ignition source prevention features during configuration changes such as modifications and repairs, or during maintenance actions,” with the adverse consequence explicitly stated, namely that failure to preserve those features “could result in a fuel tank explosion” (Background).

Temporal and procedural qualifiers appear in the Notes: Note 1 allows removal of the AWL TRs once they are superseded by a further TR or later revision to the applicable manual, which inserts a lifecycle pathway for the TRs within the Maintenance Program Manual regime. Note 2 records that Transport Canada AD CF-2008-03 is relevant (Requirement, Notes). The Directive’s compliance timeline is precise: compliance within 60 days after the effective date; the AD becomes effective on 31 January 2008 (Compliance). The instrument is signed by a CASA delegate, Charles Lenarcic, and dated 16 January 2008 (signature block).

In short, the main concepts are: CDCCL as mandatory, manufacturer-specified limitations; Temporary Revisions to the Part 2 AWL as the specification vehicle; operator amendments to Maintenance Program Manuals and procedures as the compliance action; underlying safety standards and policy instruments (Chapter 525, NPA 2002-043, Transport Canada Policy Letter No. 525-001) as the normative justification; and a 60-day compliance window with an avenue to remove TRs when formally superseded.

The Directive applies to operators of the listed Bombardier DHC-8 aeroplane models , DHC-8-102, -103, -106, -201, -202, -301, -311, -314 and -315 , and to all serial numbers of those models (Applicability). The text states the compliance obligation in the form “each operator must” perform the specified amendments to their copies of the Maintenance Program Manuals and to any related procedures or documentation (Requirement, opening clause). Therefore the primary economic actors who bear direct compliance obligations are the registered operators of those aeroplanes, not the manufacturer, although the TRs originate from the manufacturer’s Maintenance Program Manual revisions (Requirement, a).

Secondary parties affected in practice will include the organisations that perform maintenance, modifications and repairs for those operators. The Directive requires operators to “highlight the necessary requirements to maintain the design features of those CDCCL items” in their procedures and documentation (Requirement, b). That obligation will alter how maintenance organisations, line and base engineers, technical documentation providers, and quality assurance teams perform and record work for those specific airframe models insofar as they operate under the operator’s manuals and procedures. The instrument does not expressly name maintenance organisations or design approval holders, but the operational chain implicates them through the operator’s duties.

Regulatory bodies are referenced but not burdened with new tasks in the Directive text. The instrument itself is an CASA Airworthiness Directive, signed by a CASA delegate (signature block). The Background references Transport Canada’s regulatory materials (Chapter 525, NPA 2002-043 and Policy Letter No. 525-001) and notes Transport Canada AD CF-2008-03 (Note 2). That indicates cross-jurisdictional regulatory interaction, but the Directive’s direct legal duty is placed on operators covered by the Applicability statement.

Aircraft owners who are not operators (for example, lessors or owners who engage third-party operators) are not separately addressed; the text’s obligation is phrased to each operator. However, because the Directive applies to all serial numbers and requires amendments to the operator’s manuals and procedures, owners who control or influence those documents through lease provisions or operator changeovers will be practically affected. The Directive’s requirement to preserve CDCCL items during configuration changes, modifications and repairs also affects designers and approvees of modifications insofar as the operator’s amended manuals and procedures will set the constraints within which modifications may be approved and implemented.

Finally, the Directive’s safety rationale , preservation of critical fuel tank ignition source prevention features , identifies a category of benefits that accrues to passengers, crew and the public. The instrument assigns the administrative burden for preserving those features to operators via documentation and procedural controls, rather than specifying technical retrofit measures in the Directive text itself.

Duties

• Amend Maintenance Program Manuals. Each operator must amend their copies of the applicable aircraft model Maintenance Program Manuals to incorporate the CDCCL items introduced in Part 2 “Airworthiness Limitations List” of the specified Temporary Revisions: TR AWL-98 for DHC-8-100 series (PSM 1-8-7), TR AWL 2-35 for DHC-8-200 series (PSM 1-82-7), and TR AWL 3-103 for DHC-8-300 series (PSM 1-83-7) (Requirement, a(i)-(iii)). The duty is stated in mandatory language: “each operator must” amend their copies.

• Amend procedures and documentation. Each operator must amend any of their DHC-8-100, -200 and -300 Series aircraft related procedures or documentation to highlight the existence of CDCCL items noted above and to highlight the necessary requirements to maintain the design features of those CDCCL items (Requirement, b). This is an obligation to change operational documentation and/or procedural flow to ensure CDCCL items are brought to attention and their maintenance-preserving requirements are recorded.

• Comply within 60 days. The operator’s actions must be completed within 60 days after the effective date of the Directive, which is 31 January 2008 (Compliance). The deadline is fixed rather than permissive.

Rights and qualifications

• Removal when superseded. Note 1 provides a right or at least a procedural qualification: the mandated AWL TRs may be removed from the applicable Maintenance Program Manual when they are superseded by a further TR or later revision to the applicable manual. That creates an explicit lifecycle path for the TRs within an operator’s manual once a formal replacement appears (Notes).

• Cross-reference to Transport Canada AD. Note 2 records that Transport Canada AD CF-2008-03 refers. That is not framed as an operator’s right, but it situates the AD in an international regulatory context and may allow operators to consult the referenced Transport Canada AD for related obligations or guidance (Notes).

Other observations regarding duties and rights observable from the text

• The Directive prescribes documentary amendments and procedural highlighting rather than prescribing specific maintenance tasks or inspection intervals within the Directive itself (Requirement). The specific content to be incorporated is located in the manufacturer-issued TRs to the Part 2 AWL. The Directive therefore makes the operator responsible for incorporating those manufacturer-specified limitations into its own formal governance documents.

• The Background links the Directive to a system safety review and policy assessment (Background). The Directive does not itself include technical definitions of CDCCL or specify how “management and control” of CDCCL items must be carried out beyond the amendments described. In that sense, the duty is procedural and documentation-focused; the technical content that defines the obligation is external to the Directive and resides in the TRs.

• There is no express process described in the Directive text for CASA approval of the manual amendments, nor any prescribed format for the highlighting of CDCCL items in procedures and documentation. The absence of an explicit approval clause means the Directive imposes content and timing obligations but leaves the operative mechanics of amendment implementation to the operator, subject to the broader regulatory environment.

In sum, operators carry the central and time-sensitive duties to embed specified CDCCL items into their Maintenance Program Manuals and to revise related procedures and documentation to preserve the design features intended to prevent fuel tank ignition sources. The instrument affords a limited right to remove the TRs once formally superseded.

The Directive text prescribes mandatory actions and a compliance timeframe but does not specify penalties, enforcement mechanisms or sanctions within the document itself. It states that “each operator must” undertake the manual and procedural amendments and sets the compliance period as “Within 60 days after the effective date of this Directive” (Requirement; Compliance). The AD also states that it becomes effective on 31 January 2008 (Compliance). The instrument is presented as an Airworthiness Directive issued by CASA and signed by the delegated official (signature block).

Because the Directive text contains no enumerated fines, suspension mechanisms, or prescribed enforcement procedures, the document does not itself articulate explicit penalties for non-compliance. The text also does not describe how CASA will verify compliance, whether by submission and approval of revised manuals, audit, inspection, or other regulatory checks. The AD likewise does not state whether non-compliance will lead to grounding of aircraft, revocation of an approval, or prosecution under a particular statutory provision. Those matters are not addressed in the wording of the Directive as supplied.

However, the Directive’s status as an Airworthiness Directive and its mandatory language indicate that compliance is required; the presence of a compliance date and the signature of a CASA delegate confirm its regulatory provenance (Compliance; signature block). The Background and the explicit safety rationale , the stated risk of a fuel tank explosion if CDCCL items are not preserved , explain the safety policy basis for mandating action (Background). The document also cross-references Transport Canada AD CF-2008-03 (Note 2), which suggests there is parallel regulatory activity in another jurisdiction; the Directive does not specify whether CASA will employ a particular enforcement route consistent with its general regulatory powers.

For practitioners advising operators, the document’s silence on enforcement detail means that risk management should treat non-compliance as exposing the operator to regulatory intervention under CASA’s general statutory powers rather than to a specific sanction described in the AD itself. The operator should also expect that CASA may require evidence of compliance, although the AD does not set the form of evidence. The Directive does not prescribe an appeals mechanism, a certification process for manual changes, or an exemption pathway in its text.

In short, the AD imposes mandatory duties and a 60-day deadline but contains no explicit penalty schedule or enforcement procedure. The regulatory effect therefore depends on CASA’s broader statutory enforcement framework rather than on penalty clauses contained in the AD text.

The Directive situates itself against a narrow set of related regulatory instruments referenced in its Background and Notes. The Background records that Bombardier’s system safety review assessed the aircraft fuel system against fuel tank safety standards introduced in Chapter 525 of the Airworthiness Manual through Notice of Proposed Amendment (NPA) 2002-043 (Background). Non-compliances identified by that review were then assessed using Transport Canada Policy Letter No. 525-001 to determine if mandatory corrective action was required (Background). Note 2 of the Directive explicitly refers to Transport Canada AD CF-2008-03 (Notes). These cross-references indicate an intended alignment or harmonisation with the airworthiness standards and policy instruments referenced.

Mechanically, the Directive integrates manufacturer-originated Temporary Revisions to the Part 2 AWL of the Maintenance Program Manuals into operators’ manuals and procedures (Requirement, a). The Temporary Revisions are the technical specification vehicle; the Directive’s legal mechanism is to require operators to adopt them in their own manuals. This creates an interaction between the operator’s regulatory obligations under CASA and the manufacturer’s maintenance limitations: the operator’s compliance obligation is to incorporate the manufacturer-specified CDCCL items into the operator’s governing maintenance documentation.

The Directive does not reference or modify other statutes, regulations or specific CASA procedural rules in its text. It does not provide its own definitions or procedural mechanisms that would displace other legal instruments; instead, it mandates the adoption of specific Temporary Revisions and the documentation changes that bring those TRs into the operator’s control framework. Thus the functional interaction is one of procedural incorporation: the Directive makes manufacturer TRs a mandatory element of operator documentation, thereby linking the manufacturer’s technical limitations to the operator’s regulatory documentation duties.

Because the Background references Transport Canada instruments and an international standard-setting process (NPA 2002-043 and Policy Letter No. 525-001), the Directive may be read as implementing within the CASA jurisdiction a safety outcome that has been considered under Transport Canada policy and associated AD action (Note 2). The Directive itself does not specify how operators should reconcile or prioritize overlapping obligations where Transport Canada ADs, manufacturer TRs and CASA directives might differ; the text does not include a clause addressing conflicts or precedence.

Note 1 addresses lifecycle interaction with future documentation: AWL TRs mandated by the Directive “may be removed from the applicable Maintenance Program Manual when superseded by a further TR or later revision to the applicable manual.” That creates an explicit pathway for future revisions to alter the content mandated by the Directive without requiring a separate retraction of the AD itself. It therefore anticipates an interaction between ongoing manufacturer documentation updates and the operator’s compliance obligations.

In summary, within the confines of the text, interaction with other laws and instruments is limited to cross-reference and incorporation: the AD references and implements manufacturer TRs, grounds itself in Chapter 525/NPA 2002-043 standards and Transport Canada policy, and allows for removal of TRs when they are superseded. The Directive does not specify processes for resolving conflicts with other regulatory instruments or set out enforcement mechanisms beyond the directive’s own compliance requirement.

The Directive text itself contains limited material relevant to amendment history. It identifies the Temporary Revisions to the Maintenance Program Manuals that are the targeted amendments: TR AWL-98 for DHC-8-100 series (PSM 1-8-7), TR AWL 2-35 for DHC-8-200 series (PSM 1-82-7) and TR AWL 3-103 for DHC-8-300 series (PSM 1-83-7) (Requirement, a(i)-(iii)). The AD states that the AWL TRs mandated by the Directive “may be removed from the applicable Maintenance Program Manual when superseded by a further TR or later revision to the applicable manual” (Note 1). That clause is the only express mechanism in the Directive text by which the content mandated can be varied: when a manufacturer issues a formal superseding TR or a later revision to the manual, the previously mandated TRs may be removed from the operator’s manual.

The Directive itself becomes effective on 31 January 2008 and requires compliance within 60 days after that effective date (Compliance). The document is dated 16 January 2008 and bears the signature of the CASA delegate, Charles Lenarcic (signature block). The AD also references Transport Canada AD CF-2008-03 (Note 2), indicating parallel activity in another jurisdiction at the same time. There is no schedule of prior iterations or later amendments to AD/DHC-8/134 recorded within the provided text.

No further amendments, revocations, or supersessions of the AD itself are recorded in the instrument. The Directive contemplates that the content it mandates may evolve through manufacturer TRs and manual revisions, and allows operators to remove mandated TRs from their manuals once the manufacturer issues superseding documentation (Note 1). But the AD does not record any subsequent AD actions, variances, extensions, or replacement directives.

Advisers should therefore treat the Directive as a single, time-stamped regulatory instrument that incorporated specific manufacturer TRs into operator obligations as of 31 January 2008, with an operator-level conforming mechanism for removing those TRs when the manufacturer issue superseding revisions. Any later changes to the AD itself, or later CASA instruments that amend or revoke AD/DHC-8/134, are not included in the supplied text.

The text of AD/DHC-8/134 contains no litigation history, references to court decisions, administrative appeals, or case citations. It is an administrative Airworthiness Directive issued by the Civil Aviation Safety Authority delegate and includes only the directive content, Notes and Background. There are no reported legal challenges, judicial reviews, or enforcement proceedings mentioned within the document.

Because the Directive itself makes documentary and procedural mandates and does not spell out enforcement sanctions or administrative processes in its text, the absence of litigation references may reflect either that no litigation has been brought in relation to this AD or that any litigation is not recorded within the AD text. The instrument does not provide an internal register or annex that records legal disputes or prior adjudications.

For practitioners searching for litigation or precedent, the Directive as supplied does not identify any cases. It does, however, cross-reference Transport Canada AD CF-2008-03 (Note 2) and refers to the safety standards in Chapter 525 of the Airworthiness Manual and to Transport Canada Policy Letter No. 525-001 (Background). If litigation were to arise about compliance, enforcement or interpretation of the CDCCL requirements, that litigation would likely engage the specific content of the Temporary Revisions and the operator’s documentation changes rather than the AD’s text alone. The AD does not prescribe an appeals process or identify a tribunal to hear disputes arising under the Directive; such remedies would be governed by broader statutory and administrative law frameworks not set out within the directive text.

Practitioners must therefore rely on external legal research to identify any caselaw that might have emerged in relation to AD/DHC-8/134; no such cases are named or cited in the instrument itself.

Several practical and legal pitfalls arise directly from the text and structure of the Directive.

• Wide applicability, narrow text. The Directive applies to a broad set of airframe models and to “all serial numbers” of those models (Applicability). The AD therefore captures every operator of the listed models, without exception in the text. Operators may mistakenly assume limited scope; the text confirms universal applicability across serial numbers.

• Short compliance window. The Directive requires compliance “Within 60 days after the effective date of this Directive” and declares the AD effective on 31 January 2008 (Compliance). For organisations with distributed technical documentation control, multiple stakeholder sign-offs, or complex procedures for amending approved Maintenance Program Manuals, a 60-day calendar window imposes an accelerated project timeline. Delays in internal drafting, review, or operator-maintenance-provider coordination could result in non-compliance with a short statutory deadline.

• Procedural obligation without procedural detail. The AD mandates amendment of manuals and procedures to highlight CDCCL items and their necessary maintenance-preserving requirements (Requirement, b) but does not prescribe the format, content standard, approval pathway, or evidence that will satisfy CASA. The Directive does not specify whether CASA requires submission of revised manuals for acceptance, whether the operator must notify CASA when the manual is amended, or whether CASA will audit to verify compliance. That absence creates implementation risk and potential regulatory uncertainty for operators and their maintenance partners.

• Technical specifics external to the Directive. The substantive content of the required limitations is located in the manufacturer’s Temporary Revisions (TR AWL-98, TR AWL 2-35, TR AWL 3-103). The Directive does not restate those technical limitations within its own text. Operators who do not obtain and review the applicable TRs may fail to incorporate the correct CDCCL items. Reliance on the Directive alone without reviewing the referenced TRs is a common operational pitfall.

• Ambiguity of “management and control” and “highlight the necessary requirements”. The Directive’s opening sentence frames its purpose “To ensure management and control of Critical Design Configuration Control Limitations (CDCCL) items,” but the AD does not provide a definition of “management and control” nor does it specify minimal content for “necessary requirements to maintain the design features of those CDCCL items” (Requirement, opening clause; Requirement, b). Operators face interpretive risk when deciding the depth of procedural change required to meet the Directive’s standard.

• Removal mechanism conditional on manufacturer action. Note 1 states that AWL TRs “may be removed from the applicable Maintenance Program Manual when superseded by a further TR or later revision to the applicable manual.” This means that removal is contingent on the manufacturer issuing a superseding TR or revision. Operators cannot unilaterally remove the mandated TRs; removal is tied to a formal manufacturer action, which may be outside the operator’s control.

• Cross-jurisdictional reference. Note 2 refers to Transport Canada AD CF-2008-03. Operators that operate across jurisdictions or that follow different national regulatory practices must review the referenced Transport Canada AD and reconcile its requirements with CASA’s Directive. The AD does not provide guidance for harmonising differences, leaving operators to interpret and align obligations themselves.

• No penalties or enforcement detail stated. The Directive contains no explicit penalties or enforcement procedures. Some operators might misread that absence as meaning non-compliance carries no immediate consequence. Because the AD is framed in mandatory language, failure to comply will likely attract regulatory consequences under CASA’s broader enforcement powers even though the document does not specify the form of those consequences.

• Reliance on manufacturer documentation identifiers. The Directive cites specific PSM references (PSM 1-8-7, PSM 1-82-7, PSM 1-83-7). Operators should ensure they incorporate the correct documents and revisions; referencing errors or using incorrect PSM pages could produce a compliance failure.

• Potential misalignment between procedural highlighting and operational practice. The Directive requires operators to “highlight” CDCCL items in their procedures and documentation (Requirement, b). If operational practice, maintenance contracts, or local procedures are not updated to reflect those highlights, the intended safety-preserving effect may not be achieved. Mere documentary highlighting without process changes could leave the underlying risk unmitigated.

These gotchas are concrete, traceable to the Directive text and its structural features: precise applicability, detailed TR references, a short compliance window, and the absence of procedural and enforcement specifics.

A practical compliance plan grounded in the Directive text must achieve three outcomes within the specified 60-day period: incorporate the specified TRs into the operator’s Maintenance Program Manual Part 2 AWL, amend DHC-8-related procedures and documentation to highlight CDCCL items and their preservation requirements, and retain evidence of those changes. The following steps track the Directive’s wording and structure.

1. Confirm applicability and inventory. Verify whether the operator holds any DHC-8 aircraft of the listed models (DHC-8-102, -103, -106, -201, -202, -301, -311, -314, -315) and document serial numbers. The Directive applies to all serial numbers of the listed models (Applicability), so the inventory should capture every in-service and reserve aircraft that falls within those model types.

2. Obtain and review the referenced Temporary Revisions. Acquire TR AWL-98 for DHC-8-100 Series (DHC-8-100 Maintenance Program Manual, PSM 1-8-7), TR AWL 2-35 for DHC-8-200 Series (PSM 1-82-7), and TR AWL 3-103 for DHC-8-300 Series (PSM 1-83-7) (Requirement, a(i)-(iii)). The content of the CDCCL items to be incorporated is located within those TRs; compliance requires incorporation of the TR content, not merely a reference to the TR identifiers.

3. Amend the Maintenance Program Manual Part 2 AWL. For each applicable aircraft model, amend the operator’s copy of the Maintenance Program Manual to incorporate the CDCCL items introduced in the specified TR to Part 2 “Airworthiness Limitations List” (Requirement, a). Ensure the manual revisions clearly identify the CDCCL items, the limitations or constraints they impose, and any preservation requirements for design features that are necessary to prevent fuel tank ignition sources.

4. Amend related procedures and documentation. Revise any DHC-8-100, -200 and -300 Series related procedures and documentation to highlight the existence of the CDCCL items and to highlight the necessary requirements to maintain the design features of those CDCCL items (Requirement, b). This should include checklists, maintenance planning documents, modification approval procedures, repair approvals, engineering orders and any flow that could permit a configuration change affecting CDCCL items. The Directive’s wording requires highlighting and setting out the necessary requirements; operators should therefore ensure the procedural text is explicit about preservation obligations.

5. Define “management and control” measures. Although the Directive does not define the term, the operator should implement clear administrative and technical controls to ensure CDCCL items are preserved during maintenance, modifications and repairs, consistent with the Directive’s stated purpose to “ensure management and control of Critical Design Configuration Control Limitations (CDCCL) items” (Requirement, opening clause; Background). Controls may include change approval gates, engineering concurrence requirements for work affecting CDCCL items, and documentation check steps in maintenance tasks and modification records. While the AD does not prescribe these mechanics, these steps implement the AD’s purpose.

6. Maintain records and evidence of compliance. Document the manual revisions, procedure changes, the dates they were effected, the personnel who approved and implemented them, and any distribution or training undertaken as a result. The Directive does not spell out the form of evidence CASA will require, but retaining comprehensive records is a prudent means to demonstrate compliance within the 60-day window.

7. Coordinate with maintenance providers and internal stakeholders. Communicate the changes to contracted maintenance organisations, engineers, quality assurance, continuing airworthiness staff and any parties involved in modifications, repairs and airworthiness approvals. Ensure the providers integrate the CDCCL-preserving requirements into their work processes and that contractual obligations are aligned.

8. Monitor for superseding TRs. Note that AWL TRs mandated by the Directive “may be removed from the applicable Maintenance Program Manual when superseded by a further TR or later revision to the applicable manual” (Note 1). Implement a monitoring process to track manufacturer TRs and manual revisions so that, if and when superseding TRs are issued, the operator can update its manuals accordingly and remove previously mandated TRs if appropriate.

9. Review Transport Canada reference. Note 2 refers to Transport Canada AD CF-2008-03. Operators ought to consult the referenced AD where relevant, particularly for operators or flights that interact with Canadian regulatory jurisdictions, and to ensure any cross-jurisdictional differences are reconciled.

10. Implement an internal compliance check before the deadline. Before the 60-day deadline elapses, perform an internal compliance verification to confirm that the Maintenance Program Manuals and procedures have been amended in the operator’s official controlled documentation set and that records of implementation are complete.

Timing: The Directive states it becomes effective on 31 January 2008 and requires compliance within 60 days after that effective date (Compliance). Operators therefore needed to complete these steps within that statutory window. The AD is dated 16 January 2008 and is signed by the CASA delegate (signature block). Operators should ensure that their logs record the effective date and the date of completion of the mandated amendments.

Evidence for regulators: Because the AD does not set out a specific CASA submission or approval process for the manual amendments, operators should be prepared to produce revised manual pages, revision sheets, approval signatures, training records and any other documentary evidence that shows the amendments were applied to the operator’s controlled documentation set and communicated to maintenance providers and staff.

In sum, compliance is a documentary and procedural project: obtain the TRs, embed the CDCCL items into Part 2 AWL of the operator’s Maintenance Program Manual, revise procedures and documentation to highlight the CDCCL preservation requirements, retain evidence of the change, coordinate with maintenance providers, and monitor for any superseding TRs.