AD/EMB-120/47 - Fuel Booster Pump Electrical Wiring

The Directive relies on a small set of concrete technical and procedural concepts that determine what must be done, when, and to what standard.

Applicability: The AD applies only to a defined production run of EMB-120 aircraft, namely serial numbers 120001 to 120359 inclusive. That limits the universe of covered aircraft to that serial-number range; the document does not extend requirements beyond those serial numbers.

AFM limitation and maintenance restriction: The required wording to be inserted into the AFM is explicit: “The minimum fuel quantity inside each tank must be 300kg or 370 litres.” Note 1 clarifies the operational scope of the limitation: after the Directive’s effective date, “any fuel tank defueling or other maintenance action which requires use of the fuel booster pumps is limited to a minimum fuel quantity not to be less than 300kg or 370 litres inside the respective tank.” The Directive therefore converts the technical concern (harness chafing inside tanks) into a quantifiable operational constraint on fuel quantity when booster pumps are used.

Service Bulletin linkage: Both the inspection (Requirement 2) and clamp installation (Requirement 4) are to be carried out “in accordance with Embraer Service Bulletin 120-28-0016 dated 9 January 2008 or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” The Directive thus delegates the detailed inspection and installation methods to the manufacturer’s SB, but conditions the acceptability of any later SB revisions on ANAC approval. The Directive uses the SB as the technical standard without reproducing the SB’s procedures.

Replacement requirement: Requirement 3 specifies replacement of any damaged fuel booster pump “by another one with the same part number.” That limits corrective action to like-for-like replacement rather than permitting a modified or improved part unless it bears the same part number; the Directive does not address alternatives, redesigned parts, or engineering approvals beyond the same-part-number replacement.

Temporary vs permanent status: Note 2 provides a route to remove the AFM limitation and the Note 1 maintenance restriction once Requirements 2 and 4 are completed. Thus the AFM limitation is temporary pending inspection and clamp installation to the SB standard.

Timeframes and triggers: The Compliance table sets distinct time windows: AFM limitation within 30 days; inspections/clamps within 4000 flight hours or 24 calendar months or at the next time the fuel tank is opened (whichever occurs first); immediate replacement before further flight if damage found. That combination of fixed calendar, flight-hour, and event-based triggers creates multiple triggers for compliance, including the operational event of opening the tank.

Referenced foreign regulator action: The Directive explicitly references and defers to Brazilian regulator action and approvals. It notes “Note 3: ANAC AD 2008-05-01 refers,” and it allows “later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)” to satisfy inspection and installation requirements. The linkage creates an ongoing point of coordination between CASA’s AD and ANAC approvals or revisions to the SB.

Background causal premise: The Directive attaches its requirements to an incident narrative: “one occurrence of a fuel booster pump circuit breaker opening during an engine maintenance servicing has been reported. An inspection inside the fuel tank revealed the fuel booster pumps electrical harness chafing against its body, causing the loss of the electrical wiring protection and resulting in a short circuit… other fuel booster pump electrical harnesses chafing… causing damage to the harness protective layers and resulting on possible ignition source inside the fuel tank.” That background provides the safety rationale the AD sets out to mitigate.

Authority and publication details: The AD is identified as AD/EMB-120/47, dated 8/2008 DM, signed by James Coyne, Delegate of the Civil Aviation Safety Authority, dated 12 June 2008, and made effective 18 June 2008. The document itself contains no detailed penalty scheme or enforcement provision; it imposes operational and maintenance duties and links those duties to specific service-document standards.

The Directive’s text makes clear the particular stakeholders and actors who are materially affected. At the aircraft/operator level, every operator, owner or lessee of Embraer EMB-120 aeroplanes with serial numbers 120001-120359 inclusive must comply with the Directive’s requirements. The applicability statement at the head of the Directive identifies the exact serial-number range, so operators of airframes outside that range are not covered by this document as written.

Maintenance organisations and certificated maintenance personnel are directly affected by the inspection, replacement and installation obligations. Requirement 2 mandates an inspection “in accordance with Embraer Service Bulletin 120-28-0016 … or later revisions approved by ANAC.” That imposes a procedural obligation on the entity performing maintenance to follow the SB’s steps and acceptance criteria. Requirement 3 requires replacement of damaged booster pumps “by another one with the same part number,” creating a parts-supply implication for maintenance organisations and spares managers. Requirement 4 requires installation of clamps and tie-raps to attach the harness, again requiring maintenance personnel to effect the physical modification per the SB.

Flight operations and flight crews are affected through the AFM change and the fuel-quantity restriction. Requirement 1 imposes an AFM limitation that states the minimum fuel quantity inside each tank is 300 kg or 370 litres, and Note 1 applies that limitation to any fuel tank defuelling or maintenance that requires use of the fuel booster pumps. Flightcrew and ground operations personnel will need to observe this AFM limitation while performing such maintenance or ground defuelling procedures. Because the AFM limitation may be inserted by placing a copy of the Directive into the AFM, operators’ flight operations departments must ensure dissemination and incorporation of that text.

Engineering and regulatory liaisons are affected because the Directive ties compliance to a specific manufacturer service bulletin and to ANAC-approved revisions. Operators who seek to comply using later SB revisions must confirm ANAC approval status. Note 3 also indicates that ANAC AD 2008-05-01 is relevant background/reference material; entities responsible for continuing airworthiness and regulatory compliance must be aware of both CASA’s AD and the ANAC references.

Procurement and logistics staff are affected because Requirement 3’s like-for-like replacement obligation may create demand for particular part numbers. The Directive does not address alternative parts or engineering approvals; it requires replacement by a part having the same part number as the damaged pump. Therefore spares stocking and part procurement responsibilities fall to the operator or maintenance organisation.

Finally, the Civil Aviation Safety Authority is the issuing body; the Directive is signed by a CASA delegate, James Coyne. The Directive does not itself specify enforcement mechanisms or penalties within the text, but CASA’s issuance imposes a compliance expectation on operators and maintenance organisations. The Directive’s compliance dates and “before further flight” timing impose constraints that will influence scheduling of maintenance, aircraft downtime, and operational planning for affected aircraft.

The Directive sets out clear affirmative duties on operators and maintenance organisations, and it creates one explicit operational right (or removal of restriction) conditional on completing specified actions.

Primary duties

• AFM insertion duty (Requirement 1): Operators must insert the specified limitation into the AFM within 30 days of the Directive’s effective date. The Directive explicitly permits achieving this by inserting a copy of the Directive into the AFM: “this may be accomplished by inserting a copy of this Directive in the AFM.” The exact mandated wording is: “The minimum fuel quantity inside each tank must be 300kg or 370 litres.” Note 1 explains the functional effect of that AFM entry for subsequent maintenance and defuelling.

• Inspection duty (Requirement 2): Operators must inspect the fuel booster pump electrical harnesses in the LH and RH tanks “in accordance with Embraer Service Bulletin 120-28-0016 dated 9 January 2008 or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” The inspection must be done within the time trigger set out in the Compliance table: within the next 4000 flight hours or 24 calendar months or at the next time the fuel tank is opened (scheduled or unscheduled), whichever occurs first, following the Directive’s effective date.

• Corrective replacement duty (Requirement 3): If damage is found during the Requirement 2 inspection, the affected fuel booster pump must be replaced “by another one with the same part number.” The Compliance row for Requirement 3 prescribes that replacement must occur “Before further flight after the Requirement 2 inspection.” That is an immediate operational constraint: any discovered damage requires rectification before the aircraft is released to flight.

• Installation duty (Requirement 4): Operators must install clamps on the tank structure and attach each fuel booster pump electrical harness to prevent chafing, again “in accordance with SB120-28-0016 or further revisions approved by the ANAC.” The timing for Requirement 4 aligns with Requirement 2: within 4000 flight hours or 24 months or at the next tank opening, whichever occurs first.

Conditional right / removal of restriction

• Removal of AFM limitation upon completion (Note 2): The Directive expressly allows removal of the AFM limitation and the Note 1 maintenance restriction on completion of Requirements 2 and 4: “Following compliance with Requirements 2 and 4, the AFM limitations imposed by Requirement 1 may be removed from the AFM and the Note 1 maintenance restriction is no longer applicable.” That creates a clear conditional, reversible constraint: the AFM limitation is mandatory until inspections and clamp installations are done per the SB; once those corrective/mitigating measures are complete, the AFM entry can be withdrawn.

Standards and sources duty

• Use of specified SB (Requirements 2 and 4): Compliance with Requirements 2 and 4 must be to the standard of Embraer Service Bulletin 120-28-0016 dated 9 January 2008, or any later revision approved by ANAC. Operators therefore have the duty to ensure the inspection and installation methods conform to that SB or an ANAC-approved later revision.

Part-number equivalence duty

• Replacement by same part number (Requirement 3): The Directive requires replacement “by another one with the same part number,” limiting remedial action to identical-part replacement unless an identical part number is otherwise provided. The Directive does not provide a procedure for alternative parts, modifications or design changes.

Timing duties

• AFM insertion within 30 days (Compliance): “For Requirement 1 - Within the next 30 days after the effective date of this Directive.”

• Inspections/clamps within 4000 flight hours or 24 months or at next tank opening, whichever occurs first (Compliance): “For Requirement 2 and 4 - Within the next 4000 flight hours or 24 calendar months or at next time the fuel tank is opened (scheduled or unscheduled), after the effective date of this Directive, whichever occurs first.”

• Replacement before further flight after inspection (Compliance): “For Requirement 3 - Before further flight after the Requirement 2 inspection.”

Rights and flexibility

• AFM insertion method: The Directive permits insertion of the AFM limitation by simply inserting a copy of the Directive into the AFM, which may reduce procedural friction when operators implement the limitation quickly.

• Use of later ANAC-approved SB revisions: The Directive permits inspection and clamp installation to be performed in accordance with later SB revisions provided those revisions are approved by ANAC. That provides some flexibility to use manufacturer updates that ANAC accepts, while maintaining the regulator linkage.

What the Directive does not grant or specify

• The Directive does not, within its text, specify alternatives to like-for-like replacement, an extension process for compliance dates, or explicit penalty or enforcement mechanisms. The Directive also does not provide engineering approval processes for alternative means of compliance; it restricts acceptable procedures to the SB or ANAC-approved later revisions. It does not specify who is authorised to conduct the inspections beyond the SB’s requirements, nor does it expressly set record-keeping requirements in the text provided.

The text of the Directive itself does not include express penalty provisions nor does it set out an enforcement procedure. The AD records the actions mandated and their compliance timelines, but it contains no clause within the document that defines fines, legal penalties, suspension of operations, or enforcement mechanisms. The compliance table specifies required timings,Requirement 1 within 30 days, Requirements 2 and 4 within 4000 flight hours or 24 calendar months or at the next tank opening, whichever occurs first, and Requirement 3 before further flight after inspection,but the Directive’s text does not state the consequences of non-compliance.

Because the document is an instrument of the Civil Aviation Safety Authority (signed by a CASA delegate, James Coyne), the Directive imposes binding obligations as issued by that authority; however, the Directive text provided does not itself narrate enforcement powers or sanctions. The absence of penalty language in the AD means that the document should be read as prescribing mandatory airworthiness actions and timelines, while any specific enforcement steps, sanctions, or administrative processes for non-compliance would be governed by the issuing regulator’s broader statutory powers and enforcement framework rather than by the text of the AD. The Directive does not reproduce or reference those statutory enforcement provisions within the text supplied.

Operationally, the Directive contains an explicit operational constraint and a “before further flight” condition. Specifically, Requirement 3’s placement in the Compliance table mandates replacement of any damaged booster pump found during the Requirement 2 inspection “Before further flight after the Requirement 2 inspection.” That phrasing imposes an immediate operational restriction: if damage is found during the mandated inspection, the aircraft cannot legally be returned to flight until the replacement action has been completed. The AD therefore creates an operational enforcement lever embedded in the compliance timing: an aircraft with unrectified damage discovered under the AD’s inspection is not permitted to fly until compliance is achieved. Beyond that operational lever, the Directive’s text does not provide fines, civil penalties, or criminal sanctions; references to formal enforcement powers or penalty regimes are not present in the document provided.

Finally, the Directive references ANAC AD 2008-05-01 (Note 3) and ties technical compliance to Embraer Service Bulletin 120-28-0016 or later revisions approved by ANAC. That means a failure to meet the SB’s inspection or modification standards would likely be clear non-compliance with the AD’s substantive technical requirements, but the AD itself does not specify the mechanism by which CASA would determine or record enforcement action. Any reader seeking explicit enforcement and penalty detail must therefore consult the regulator’s enforcement statutes, policies, or subsequent CASA guidance, none of which are reproduced within the Directive text provided.

Within the four corners of the Directive, interaction with other instruments is limited to specific references to the manufacturer’s Service Bulletin and to a Brazilian regulator action. The AD expressly conditions its technical compliance methods on Embraer Service Bulletin 120-28-0016 dated 9 January 2008, and on any “later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” Note 3 explicitly refers to “ANAC AD 2008-05-01.” Thus, the Directive interacts with three external documentary sources:

• Embraer Service Bulletin 120-28-0016 (dated 9 January 2008): The AD delegates the detailed inspection and installation methodology to this SB. Compliance with Requirements 2 and 4 must be “in accordance with” that Service Bulletin. Consequently, the AD’s technical obligations are contingent on the content of the SB; the AD does not restate the SB procedures. Any operator who wishes to demonstrate compliance must have regard to the SB’s specific inspection steps, acceptance criteria, torque values, clamp placement guidance, or other technical details that the SB contains.

• Later SB revisions subject to ANAC approval: The AD allows use of later revisions of the SB provided those revisions are approved by ANAC. That introduces a cross-jurisdictional approval gate: an SB revision acceptable to Embraer but not approved by ANAC would not, under the AD’s text, be an authorised means of compliance. The Directive therefore creates a regulatory linkage that requires coordination between an operator or maintenance organisation and the Brazilian authority’s approvals process for future SB revisions.

• ANAC AD 2008-05-01: The Directive’s Note 3 states that ANAC AD 2008-05-01 is referenced. The AD does not reproduce ANAC AD 2008-05-01, nor does it explain differences between the two documents; it simply acknowledges the existence of the ANAC AD as related material. The AD’s allowance of ANAC-approved SB revisions and reference to ANAC AD suggests that the Brazilian regulator’s findings and remedial instructions were part of the genesis of CASA’s AD and remain a point of technical coordination.

Beyond those explicit cross-references, the Directive does not reproduce or cite other laws, regulations, or statutory enforcement powers. It does not, within its text, address how compliance with the AD interacts with broader statutory obligations such as continuing airworthiness record-keeping, air operator certificate conditions, or maintenance organisation approvals. The document therefore leaves open the question of how CASA’s AD will be integrated into operators’ continuing airworthiness management systems, maintenance release processes, or their record-keeping practices, though it imposes concrete work and AFM-change obligations that will necessarily be recorded in an operator’s technical records.

The AD’s operational linkage to the AFM also has interactional implications. The AFM is an aircraft-specific operational manual used by crews and operators; an insertion of a mandatory limitation into the AFM changes operational practice. The AD permits the limitation to be inserted by placing a copy of the Directive in the AFM, but it does not specify the procedural means by which flight operations or training departments must promulgate the change, nor does it specify how the AFM change interacts with air operator procedures. Those interactions will be managed by operators under their own procedures, but the AD itself does not outline them.

In short, the AD interacts explicitly with a manufacturer Service Bulletin and with a Brazilian regulator AD and approval process. It does not, in the text provided, describe interactions with domestic enforcement statutes or with operators’ continuing airworthiness obligations; those areas will need to be addressed by the operator or by reference to CASA’s broader regulatory framework outside the AD text.

The document supplied does not record any subsequent amendments to the Directive itself. The AD identifies its issue as “AD/EMB-120/47 | Fuel Booster Pump Electrical Wiring | 8/2008 DM” and records that it “becomes effective on 18 June 2008.” The signature block shows the AD was signed by James Coyne, Delegate of the Civil Aviation Safety Authority, dated 12 June 2008. No later amendment, repeal, variation, or superseding entry is included in the text provided.

The Directive does, however, create a built-in tolerance for technical updates by referencing Embraer Service Bulletin 120-28-0016 dated 9 January 2008 “or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” That provision means that although the AD itself is not amended, an operator may perform Requirements 2 and 4 in accordance with later revisions of the SB provided those revisions have ANAC approval. The AD therefore anticipates technical evolution of the manufacturer’s instructions without requiring formal amendment of the AD for each SB revision; the AD ties acceptability to ANAC approval.

Note 3’s reference to ANAC AD 2008-05-01 indicates that the Brazilian authority had an action or directive relevant to this subject in May 2008. The AD does not indicate whether CASA’s AD was a verbatim adoption, an adaptation, or a separate instrument responding to the same event. The AD text does not indicate any prior versions of CASA’s AD/EMB-120 series entries nor any edits or earlier drafts.

If future modifications to the AD occur they are not contained in the source material provided. Therefore users relying on this Directive should confirm current status with the Civil Aviation Safety Authority and check for any later CASA ADs, variations, or superseding guidance that may have been issued after the effective date. The AD does allow the practical avenue of using later ANAC-approved SB revisions for Requirements 2 and 4, which may reduce the need for formal amendment of the AD when the SB evolves.

The Directive text does not reference any litigation, court challenges, or judicial review relating to this AD. There are no cases named, no citations to legal proceedings, and no mention of disputes in the document supplied. The background narrative recounts an operational occurrence (a circuit breaker opening and subsequent inspections revealing harness chafing) as the safety rationale for the AD, but it does not indicate any legal proceedings arising from that occurrence.

Because the Directive does not include litigation references or annexes documenting disputes, the document contains no judicial determinations of its validity, no administrative appeals within the text, and no case law that interprets or applies this particular AD. Therefore, as of the text supplied, there is no litigation history recorded in the AD itself.

Practitioners seeking to know whether this AD has been subject to legal challenge, or whether enforcement actions under the AD have been litigated, will need to consult external legal databases, CASA administrative records, or court records. Such sources are not part of the Directive text provided and are therefore not summarised here.

Several concrete operational and compliance pitfalls arise directly from the AD’s text and its structure.

Limited applicability by serial number: The AD applies only to EMB-120 aircraft serial numbers 120001-120359 inclusive. Operators must verify serial numbers carefully. Aircraft outside that serial-number range are not covered by this Directive as written; conversely, operators of aircraft within the range must not assume that a partial fleet exemption exists.

AFM insertion mechanics and interpretation: The AD permits insertion of a copy of the Directive into the AFM as a means of complying with Requirement 1. That may be an expedient compliance step, but operators should confirm whether their internal procedures or air operator approvals require a different AFM amendment process or formal update. The Directive’s permission to insert a copy does not obviate any operator-specific approvals that may be required for AFM changes under their operations specifications.

Scope of the AFM restriction: Note 1 frames the AFM limitation to apply to “any fuel tank defueling or other maintenance action which requires use of the fuel booster pumps,” and it states the minimum fuel quantity as “300kg or 370 litres inside the respective tank.” Operators should ensure that ground procedures, defuelling checklists, and maintenance cards reflect this quantitative threshold. Confusion may arise around the unit equivalence or whether fuel gauges and practices reliably measure to the specified amount; satisfying the numerical threshold in practice may require particular measuring or monitoring steps.

Conditional removal of limitation: Note 2 allows the AFM limitation to be removed following compliance with Requirements 2 and 4. Practitioners should ensure records document completion of the required inspections and clamp installations per the Service Bulletin before deleting the AFM statement. Deleting the AFM limitation prematurely would be non-compliant with the AD.

Timing triggers combine hours, calendar, and event-based triggers: Requirements 2 and 4 must be accomplished “within the next 4000 flight hours or 24 calendar months or at next time the fuel tank is opened (scheduled or unscheduled), whichever occurs first.” This tri-part trigger structure means that opening a fuel tank for any reason before the calendar or flight-hour limits will accelerate the compliance deadline. Maintenance planners must monitor tank-opening events carefully, because an unscheduled tank opening could trigger an immediate compliance obligation.

Replacement limited to same part number: Requirement 3 mandates replacement by another pump “with the same part number.” Operators seeking to use an upgraded or redesign part number will need to secure an approval path that the AD does not provide. The AD does not discuss engineering orders, alternative means of compliance, or modification approvals; reliance on an alternative part number without documented approval would not appear to meet the AD’s literal requirement.

Dependence on Service Bulletin and ANAC approval: The AD delegates to Embraer SB 120-28-0016 the technical procedures for inspection and installation, and it allows later SB revisions only if ANAC approves them. That creates the risk that an operator may find an updated Embraer SB but cannot use it for compliance until it is ANAC-approved. Operators must check both the SB revision status and ANAC approvals before relying on a later SB revision for compliance.

No penalties in the AD text: The AD does not set out penalties or an enforcement mechanism. That may create operational uncertainty about the regulator’s practical enforcement approach. The AD does, however, embed an operational prohibition via the “Before further flight” requirement, which has immediate practical consequences when damage is found. Stakeholders should not assume the absence of penalty text relieves them of legal obligations under CASA’s broader regulatory regime; the AD does not describe enforcement mechanisms or sanctions.

Record-keeping and auditability: The AD does not within its text specify explicit record-keeping requirements for the inspections, replacements or clamp installations. Operators must ensure their maintenance records adequately document compliance with the AD and with the SB to provide an auditable trail even though the AD does not itself set a record form or duration.

Potential operational disruption when tanks are opened: Because Requirements 2 and 4 may be triggered by any tank opening, scheduled or unscheduled, operators that encounter an unplanned tank opening will need to carry out the SB inspection and clamp installation within that event. That may increase unscheduled downtime, particularly if parts or clamps are not immediately available.

International coordination issues: The AD references ANAC approvals and ANAC AD 2008-05-01. When dealing with later SB revisions or manufacturer guidance, operators must ensure alignment with the ANAC approval status in addition to Embraer documentation and CASA expectations.

The Directive lays out a practical sequence. The following step-by-step checklist maps the AD’s requirements and compliance timings to implementable actions. Each item references the AD’s numbered requirements and the Compliance table.

1. Identify affected aircraft

   • Confirm serial numbers. The AD applies to EMB-120 aircraft serial numbers 120001 to 120359 inclusive (Applicability). Only those airframes are in scope.

2. Insert AFM limitation (Requirement 1)

   • Within 30 days of the AD’s effective date (the AD states “For Requirement 1 - Within the next 30 days after the effective date of this Directive”), insert into the AFM’s Limitations section the mandated statement: “The minimum fuel quantity inside each tank must be 300kg or 370 litres.”
   • The AD permits accomplishing this by inserting a copy of the Directive into the AFM: “this may be accomplished by inserting a copy of this Directive in the AFM.” Operators should also ensure that flight crews and ground staff are notified of the new AFM limitation and that affected operational checklists are updated accordingly.

3. Schedule and prepare for SB-based inspection (Requirement 2)

   • Plan the required inspection of the fuel booster pump electrical harnesses in LH and RH tanks in accordance with Embraer Service Bulletin 120-28-0016 dated 9 January 2008, or a later revision if that later revision has been approved by ANAC.
   • Meet the compliance trigger: complete the inspection within 4000 flight hours or 24 calendar months or at the next time the fuel tank is opened (scheduled or unscheduled), whichever occurs first.
   • Ensure maintenance personnel have the SB text available and are qualified to perform in-tank inspections per the SB instructions.

4. Be ready to replace damaged pumps immediately (Requirement 3)

   • If any damage is found during the Requirement 2 inspection, replace the affected fuel booster pump with another unit that has the same part number. The AD requires replacement “by another one with the same part number.”
   • Complete any required replacement “Before further flight after the Requirement 2 inspection.” Maintain documentation showing the inspection discovered damage and that the like-for-like replacement was completed prior to return to service.

5. Install clamps and attach harnesses (Requirement 4)

   • Install clamps on the tank structure and attach each fuel booster pump electrical harness at the LH/RH fuel tanks to prevent chafing, “in accordance with SB120-28-0016 or further revisions approved by the ANAC.”
   • Perform this installation within the same compliance window as the inspection (4000 flight hours or 24 months or at the next tank opening, whichever occurs first).
   • Ensure clamps and tie-raps used meet the SB requirements and are documented.

6. Record and document compliance

   • Keep maintenance records that document insertion of the AFM limitation (including date and method), the SB inspection findings, any replacements with part numbers recorded, and the installation of clamps and harness attachments per the SB.
   • Retain evidence that replacements were performed before further flight in cases where Requirement 3 was triggered.

7. Remove AFM limitation when permitted (Note 2)

   • After completing Requirements 2 and 4 in accordance with the SB, the operator may remove the AFM limitation and the Note 1 maintenance restriction. Ensure that documentation evidences completion of those requirements per the SB before removing the AFM statement. The AD states: “Following compliance with Requirements 2 and 4, the AFM limitations imposed by Requirement 1 may be removed from the AFM and the Note 1 maintenance restriction is no longer applicable.”

8. Coordinate for SB revisions and ANAC approval

   • If choosing to use a later revision of Embraer Service Bulletin 120-28-0016, confirm that the revision is approved by ANAC, as the AD conditions compliance on ANAC approval for later SB revisions. Maintain records showing the applicable SB revision and the ANAC approval reference if a revision is used.

9. Plan parts and logistics

   • Because Requirement 3 requires replacement by a pump with the same part number, check spares inventory and procurement lead times to ensure that a same-part-number replacement can be installed without undue delay if damage is found during inspection. Consider stocking the particular part number if multiple aircraft are affected.

10. Operational planning for tank openings

    • Recognise that an unplanned fuel-tank opening activates a compliance obligation under the AD’s “at next time the fuel tank is opened” trigger. When performing other work that requires tank opening, combine that work with the AD-mandated inspection and clamp installation to avoid repeat tank entries. Make scheduling and resource allocation decisions accordingly.

11. Verify regulatory references for completeness

    • The AD references ANAC AD 2008-05-01 and the Embraer SB. Ensure maintenance and regulatory teams have copies of these referenced documents and any ANAC approval records for later SB revisions relied upon for compliance.

12. Maintain communication with CASA

    • Although the AD does not state enforcement details within its text, maintain liaison with CASA (or the relevant delegated authority) regarding compliance status, especially if technical issues arise (for instance, the need for an engineering approval to use an alternative part number). Document any communications with CASA or its delegates concerning compliance or acceptable alternatives.

Following these steps will implement the actions mandated by AD/EMB-120/47 and document compliance so that the AFM limitation can be rescinded when Requirements 2 and 4 are completed in accordance with the referenced SB or an ANAC-approved SB revision. The AD’s Compliance table and the explicit “Before further flight” requirement for detected damage should be treated as binding operational constraints in maintenance and return-to-service workflows.