AD/EMB-145/22 - Landing Gear Electronic Unit

The AD uses a small set of concrete regulatory concepts and mechanisms. These are: applicability by model and part number; serial-number stratification; mandatory replacement with a specified new part number; incorporation by reference of manufacturer service bulletins; conditioned acceptance of later SB revisions only when approved by a foreign regulator (ANAC); staged compliance deadlines; an absolute prohibition on future installation; and an incident-based safety justification.

Applicability: The AD applies to "EMB-135 and EMB-145 series aeroplanes equipped with Landing Gear Electronic Unit (LGEU) part number (P/N) 355-022-002." The operational trigger is the presence of that specific P/N on an applicable model. The AD therefore defines the universe of affected aircraft by aircraft type combined with installed component P/N.

Serial-number stratification: The AD treats S/Ns differently. Requirement 1 targets units with S/Ns "from 1000 to 1999" and requires replacement within 12 months. Requirement 2 covers any remaining S/Ns of the same P/N and requires replacement within 30 months. This stratification imposes a stricter deadline on a named serial-number cohort, and a longer window for other serial numbers, while ultimately requiring replacement of all P/N 355-022-002 units.

Mandatory P/N swap and prohibition on reinstallation: All affected units must be replaced by LGEU P/N 355-022-003. Additionally, the AD imposes "may not be installed on any aeroplane as either a replacement spare or new installation" for P/N 355-022-002 after the stated date (after 12 September 2011). Consequently, operators must not only replace in-service units within the timeframes but must also prevent subsequent reinstallation or use of that part as a spare beyond the ban date.

Incorporation by reference and approval conditioning: The technical work must be performed "according to the detailed instructions and procedures described in the Embraer Service Bulletins (SB) 145-32-0120 original issue or 145LEG-32-0032 original issue, as applicable, or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." The AD therefore imports the manufacturer's procedural detail by reference and conditions acceptance of later revisions on ANAC approval. The AD also cross-references "ANAC AD 2009-01-01 and Errata."

Compliance timing and effective date: The AD sets two compliance windows (12 months and 30 months) measured from the AD's effective date, which the AD records as 12 March 2009. The staged deadlines create scheduling constraints for operators and maintenance organisations.

Safety justification and incident description: The AD’s background records a single incident in which landing gear indications were inconsistent,three green lights then an "LG/LEVER DISAGREE EICAS" message,leading to a go-around and momentary settling onto the flaps and belly. The AD states this "may occur in other aeroplanes of the same type and affects flight safety," which is the regulatory rationale for mandatory corrective action.

Authority and signature: The AD is issued under the authority of the Civil Aviation Safety Authority, with the document signed by "James Coyne, Delegate of the Civil Aviation Safety Authority" dated 27 January 2009. The AD also identifies itself with code "AD/EMB-145/22."

Interaction with foreign regulator and manufacturer: The text ties Australian compliance to service bulletins from Embraer and to approvals by Brazil’s ANAC. Those links mean that Australian operators must follow Embraer SB procedures and ensure that any later SB revisions they rely on carry ANAC approval as required by the AD.

Document identifiers: The AD is named in multiple repeated lines as "AD/EMB-145/22," includes the subject "Landing Gear Electronic Unit," and records issue identifier "3/2009." It also contains the two Embraer SB references: "145-32-0120" and "145LEG-32-0032."

These are the building blocks that make the AD operationally executable: identify aircraft with P/N 355-022-002, check serial numbers, schedule replacement per the relevant SB and approved revisions, and ensure no reinstallation of the banned P/N after 12 September 2011.

The AD explicitly affects owners, operators and maintenance providers of Embraer EMB-135 and EMB-145 series aeroplanes that have LGEU P/N 355-022-002 installed. The applicability clause states: "Applicability: EMB-135 and EMB-145 series aeroplanes equipped with Landing Gear Electronic Unit (LGEU) part number (P/N) 355-022-002." Therefore, the population of affected parties consists of those actors who: (a) possess or operate the specified aircraft type, and (b) have the identified part number installed.

Operators must determine whether each aeroplane in their fleet is "equipped with" the listed P/N. That determination requires checking the aircraft’s parts records, maintenance logbooks and the physical unit to identify the LGEU part number and serial number. For units with P/N 355-022-002, the AD further distinguishes between serial-number cohorts: S/Ns 1000-1999 fall under the shorter compliance window ("within the next 12 months after the effective date"), and all other S/Ns of the same P/N fall under the longer compliance window ("within the next 30 months after the effective date").

Maintenance organisations and certifying staff who perform the replacement work are affected operationally because the AD mandates that replacements be done "according to the detailed instructions and procedures described in the Embraer Service Bulletins (SB) 145-32-0120 original issue or 145LEG-32-0032 original issue, as applicable, or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." That means maintenance providers must obtain the specified SBs and ensure that any later SB revisions they intend to use are approved by ANAC, as required by the AD; otherwise the AD’s conditions are not satisfied.

Supply-chain actors are indirectly affected. Parts suppliers, spares managers and installers must recognise that from "After 12 September 2011" the AD forbids installation of LGEU P/N 355-022-002 "as either a replacement spare or new installation." Consequently, inventory decisions, procurement and spare-parts policies for organisations that service EMB-135/145 fleets will be constrained. Anyone retaining P/N 355-022-002 spares must ensure they are not installed after the prohibition date.

Regulatory interfaces: The AD ties Australian compliance to Embraer SBs and to approvals by Brazil’s ANAC, as the AD requires later SB revisions to be "approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." That cross-reference means that affected Australian operators and maintenance organisations must coordinate with or monitor ANAC approvals and Embraer service documentation in addition to CASA communications.

Finally, CASA itself (through its delegate) is the issuing authority, as shown by the signature "James Coyne, Delegate of the Civil Aviation Safety Authority." While the AD text does not set out enforcement mechanisms or penalties, CASA is identified as the issuing body and therefore is the regulator to which operators must be accountable for compliance.

Duties

• Identify applicability: Operators must determine whether an EMB-135 or EMB-145 in their fleet is "equipped with Landing Gear Electronic Unit (LGEU) part number (P/N) 355-022-002," because the AD applies only where that P/N is installed. The applicability clause is the threshold duty that triggers the remainder of the AD’s obligations.

• Replace specified units: Operators must replace the affected units with LGEU P/N 355-022-003, following the exact procedural references the AD prescribes:

  • Requirement 1: "Replace any LGEU P/N 355-022-002 with serial number (S/N) from 1000 to 1999 with LGEU P/N 355-022-003, according to the detailed instructions and procedures described in the Embraer Service Bulletins (SB) 145-32-0120 original issue or 145LEG-32-0032 original issue, as applicable, or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)."
  • Requirement 2: "Replace any LGEU P/N 355-022-002 with any S/N not included in Requirement 1 with LGEU P/N 355-022-003, according to the detailed instructions and procedures described in the SB 145-32-0120 original issue or SB 145LEG-32-0032 original issue, as applicable, or later revisions approved by the ANAC."

• Observe compliance windows: The AD sets deadlines:

  • For Requirement 1: "Within the next 12 months after the effective date of this Directive." Given the AD records the effective date as 12 March 2009, the deadline for S/Ns 1000-1999 is 12 March 2010.
  • For Requirement 2: "Within the next 30 months after the effective date of this Directive," which, from 12 March 2009, becomes 12 September 2011.

• Cease installation of the older P/N: The AD requires that "LGEU P/N 355-022-002 may not be installed on any aeroplane as either a replacement spare or new installation." The timing given is "After 12 September 2011," so operators and maintainers must not fit that part after that date.

• Use of authorised SB revisions: Where the work is to be performed using a later revision of the Embraer SBs, the AD conditions acceptance on those later revisions being "approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." Thus operators must ensure that the version of the SB used is either the "original issue" named in the AD or a later ANAC-approved revision.

Rights and clarifications implied by the text

• Right to use later ANAC-approved SB revisions: The AD does not insist the original issue SBs be used; it allows "later revisions approved by the Brazilian ANAC." That creates a procedural right for operators to use more recent SB revisions so long as they carry ANAC approval.

• Timing certainty: The AD provides explicit compliance windows and a proscriptive ban date for reinstallation, so operators have fixed dates to schedule work and procurement, avoiding open-ended regulatory uncertainty.

• Cross-reference to ANAC AD: The AD includes "Note: ANAC AD 2009-01-01 and Errata refers." While the AD does not state the legal effect of that ANAC AD, it recognises and directs attention to corresponding foreign regulatory material. The AD gives a right to rely on ANAC-approved revisions of the SBs, but does not delegate authority to ANAC to alter CASA’s deadlines.

Limitations in the AD text

• The AD does not specify who pays for the replacement or how costs are to be recovered. The text imposes an obligation to replace, but it is silent on funding, making cost allocation a matter for operators and their commercial arrangements.

• The AD does not set out enforcement mechanisms, penalties or certification consequences in the text provided. It records the issuing authority (CASA) and the signature of its delegate, but the AD itself is silent on sanctioning language. Parties seeking clarity about enforcement consequences must seek the regulator’s guidance or relevant statutory framework outside the AD text.

Operational consequences of duties

• Scheduling and maintenance planning: Operators must plan to obtain Embraer SBs, schedule the replacements within the stated windows, and ensure maintenance staff are able to perform the work in compliance with the manufacturer’s procedures or later ANAC‑approved revisions.

• Parts management: The ban on future installation of P/N 355-022-002 after 12 September 2011 requires changes to spare‑parts inventories and procurement practices.

• Documentation and verification: Because the AD requires compliance "according to the detailed instructions and procedures described in the Embraer Service Bulletins," operators must ensure that the maintenance actions are recorded and performed in accord with those SB procedures; the AD’s acceptance of later ANAC-approved revisions means operators must also verify that any non-original SB used was approved by ANAC.

The AD text provided does not contain explicit penalty provisions or an enforcement section setting out sanctions, administrative fines or criminal consequences for non-compliance. The document records the issuer and effective date,"This Airworthiness Directive becomes effective on 12 March 2009",and is signed by "James Coyne, Delegate of the Civil Aviation Safety Authority" on 27 January 2009, which identifies the issuing regulator. However, within the AD text itself there is no statement of how CASA will enforce the requirement, the processes for evidence of compliance to be lodged, or the remedies available to the regulator in the event of non-compliance.

What the AD does specify for enforceable behaviour are the prescriptive actions and dates: the replacement obligations (Requirements 1 and 2), the ban on installation after 12 September 2011 (Requirement 3), and the linking of procedural compliance to specific Embraer Service Bulletins or later ANAC-approved revisions. These prescriptive provisions create compliance obligations. In practice, in regulatory systems of this type, non-compliance with an AD can be relevant to airworthiness certification, operational authorisations and other regulatory instruments enforced by the civil aviation authority. The AD itself does not set out that regime, so the AD’s text leaves the enforcement mechanism to CASA’s broader regulatory powers or to related statutory frameworks not printed in the AD.

Because the AD lacks an enforcement clause, parties requiring certainty should consult CASA guidance or the statutory aviation legislation under which ADs are issued to determine: (a) how CASA monitors or audits compliance, (b) what documentation (for example, maintenance release documents or logbook entries) CASA will accept as proof of compliance, and (c) what penalties or administrative actions may follow sustained non-compliance. The AD references Embraer SBs and ANAC approvals; adherence to these technical documents will be the principal evidence of technical compliance, but the AD does not indicate how CASA expects evidence to be recorded or submitted.

In the absence of explicit penalties within this AD, affected parties should treat the stated replacement obligations and prohibition on installing the older unit as binding operational requirements. The AD ties compliance timing to a clear effective date (12 March 2009) and sets deadlines (12 months and 30 months) and a ban date (after 12 September 2011). Those dates establish concrete milestones that CASA could reasonably use when assessing an operator’s compliance status. Any question about enforcement, the scope of acceptable evidence, remedies for late compliance, or transitional arrangements must be resolved by reference to CASA’s regulations and administrative practice rather than by relying on penalty language within the AD itself.

This AD explicitly cross-references foreign regulatory material and Embraer service documentation, embedding a web of interactions between the Australian regulator (CASA), the manufacturer (Embraer) and the Brazilian regulator (ANAC). The AD includes a note: "ANAC AD 2009-01-01 and Errata refers." It also allows the use of "later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)" of the specific Embraer Service Bulletins named: SB 145-32-0120 and SB 145LEG-32-0032. That means the AD interacts with, and depends on, three other categories of instrument or authority:

1. Manufacturer service bulletins (Embraer SBs): The AD does not reproduce the technical procedures; instead it incorporates them by reference, instructing operators to perform the replacement "according to the detailed instructions and procedures described in the Embraer Service Bulletins (SB) 145-32-0120 original issue or 145LEG-32-0032 original issue, as applicable." Technically, the AD imports the content of those SBs into the compliance regime for Australian operators.

2. Foreign regulator approvals (ANAC): The AD conditions the use of later SB revisions on approval by ANAC. It therefore imports ANAC’s role as an approving authority: an operator can use a later SB revision only if ANAC has approved that revision. This introduces a cross-jurisdictional dependency: the Australian AD defers to ANAC’s approval of SB revisions rather than requiring CASA approval of SB revisions explicitly.

3. ANAC AD and errata: The AD notes "ANAC AD 2009-01-01 and Errata refers." That indicates there is a corresponding ANAC AD which the CASA AD recognises or references, but the CASA AD does not reproduce that ANAC AD. The CASA AD thereby situates itself in international regulatory dialogue, but it does not delegate rulemaking authority to ANAC; it simply conditions the acceptability of SB revisions on ANAC approval.

Beyond these specific cross-references, the AD is silent about interaction with other Australian statutes, such as the Civil Aviation Act, airworthiness regulations, or broader safety legislation; those statutory frameworks are not quoted or summarised in the AD text provided. Therefore, the AD stands as a technical, instrument-specific requirement that must be read together with the broader Australian aviation regulatory framework to determine consequences of non-compliance, enforcement pathways and certification implications.

Interaction points operators should note, drawn from the AD content:

• Approval provenance matters: Because only ANAC-approved later SB revisions are acceptable, operators who wish to use a more recent SB must check ANAC’s records for approval. The AD does not say CASA will independently approve later revisions, so operators will need to verify ANAC approval in addition to possessing or following the SB.

• Alignment with manufacturer instructions: The AD requires adherence to Embraer SBs for the physical work. That means staying current with Embraer instructions and ensuring those instructions used are the versions permitted under the AD.

• Cross-referencing of foreign ADs and errata: The reference to "ANAC AD 2009-01-01 and Errata" implies there may be additional or clarifying material in those documents that is relevant to compliance, so operators should consult those ANAC materials as part of their compliance process.

• Administrative recordkeeping and certification: While the AD does not set out CASA’s administrative tracking process, the requirement that work be performed "according to the detailed instructions" implies that maintenance releases and records should reflect conformance with the specified SB. Those records will likely be the interface between operator compliance and CASA oversight, but the precise legal requirements for record creation and retention are not set out in the AD text.

In short, the AD does not operate in isolation: it imports Embraer technical guidance and conditions the use of revised guidance on ANAC approval. To understand the full legal and operational effect, operators must read the AD alongside the named Embraer SBs, the referenced ANAC AD and errata, and the broader Australian aviation regulatory instruments under which CASA administers airworthiness and operational oversight.

The AD text provided records a limited but explicit set of issuance dates and identifiers; it does not contain any further amendment entries. The recorded chronology and identifiers in the AD are as follows:

• AD identifier: AD/EMB-145/22. This code appears multiple times in the document.
• Subject heading: "Landing Gear Electronic Unit" is recorded repeatedly as the subject matter of AD/EMB-145/22.
• Issue identifier and date stamp: The AD carries "3/2009" which serves as an issue marker and indicates the year and a sequence tag for the AD issuance.
• Signature and date: The AD shows "James Coyne, Delegate of the Civil Aviation Safety Authority" with the date of signature recorded as "27 January 2009."
• Effective date: The AD states "This Airworthiness Directive becomes effective on 12 March 2009." That effective date sets the temporal baseline against which the compliance windows are measured.
• Compliance timeframes: The AD sets explicit compliance windows of 12 months and 30 months from the effective date for Requirement 1 and Requirement 2 respectively, and a prohibition on installation "After 12 September 2011" for Requirement 3.

The AD also references external documents which may themselves have amendment histories: specifically, Embraer Service Bulletins "145-32-0120 original issue" and "145LEG-32-0032 original issue," and the ANAC AD "2009-01-01 and Errata." The AD allows later revisions of the Embraer SBs only if they are "approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." The allowance for later ANAC-approved revisions is the only mechanism in the AD text that contemplates technical document updates post-issuance; it does not provide for formal amendment of the AD itself.

No explicit amendments to the CASA AD are recorded in the source provided. There is no section titled "amendments" or a list of revisions to the AD, nor is there any text altering the effective date, the requirements, or the compliance timelines within the AD material supplied. Therefore, based solely on the text provided, the AD’s amendment history consists only of its initial issuance: signed 27 January 2009 and effective 12 March 2009, with compliance windows and prohibition dates calculated from that effective date.

Operators and advisers should note that the AD allows technical update by means of later ANAC-approved SB revisions, but any formal amendment of the AD (for example, extension of compliance windows, modification of requirements or rescission) is not documented within this AD. To establish whether CASA subsequently amended or superseded the AD, a search of CASA’s AD repository or formal amendment notices would be required; that information does not appear in the AD text provided.

The AD text supplied contains no litigation history. It does not reference any judicial decisions, legal challenges, or administrative appeals related to AD/EMB-145/22. There are no citations to court cases, administrative tribunal determinations, or litigation outcomes in the document.

The AD does, however, record a safety incident as the factual basis for the directive: a report that following selection of the landing gear lever to down, the crew observed three green landing gear indicating lights followed by the "LG/LEVER DISAGREE EICAS message." The crew elected to continue approach and landing; subsequently they identified that the landing gear had not been extended properly, executed a go-around successfully, and the aeroplane "settled momentarily onto the flaps and belly." The AD states: "Since this condition may occur in other aeroplanes of the same type and affects flight safety, a corrective action is required." That factual record is the operational basis for the AD, but it is not litigation.

Because the document does not include litigation references, readers interested in any legal disputes arising from the AD (for example, appeals against CASA enforcement action, judicial review of the AD, or disputes over cost recovery for compliance) must consult external sources , court databases, tribunal records, or CASA’s public records , to determine whether any litigation occurred after issuance. The AD text itself neither reports nor anticipates litigation.

The AD contains several operational and legal details that can be easy to miss, and each can carry practical consequences for operators, maintenance providers and inventory managers.

1. Applicability is P/N-specific and model-specific: The AD applies only to "EMB-135 and EMB-145 series aeroplanes equipped with Landing Gear Electronic Unit (LGEU) part number (P/N) 355-022-002." If a plane is an EMB-145 but has a different LGEU P/N, the AD does not apply. Conversely, a plane that is neither an EMB-135 nor EMB-145 is outside the AD even if it uses the same LGEU. Accurate parts and records checks are therefore essential.

2. Serial-number stratification affects scheduling: Requirement 1 applies to S/Ns "from 1000 to 1999" with a 12‑month compliance window after the AD’s effective date. Requirement 2 covers "any S/N not included in Requirement 1" with a 30‑month window. Operators must correctly identify the serial number cohort for each unit; misclassification could lead to missed deadlines.

3. Two different SB references are specified: The AD refers to two Embraer SBs,"145-32-0120 original issue" and "145LEG-32-0032 original issue",and says to follow the "original issue or" later revisions approved by ANAC. In practice this creates a need to determine which SB is "applicable" to a given aircraft or installation and to obtain the correct document. Using the wrong SB, or an SB revision without checking ANAC approval, risks non-compliance with the AD’s procedural requirement.

4. Later SB revisions are acceptable only if ANAC-approved: The AD is explicit that later revisions of the SBs are acceptable "as applicable, or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." That means operators cannot simply follow a later Embraer SB revision unless it has ANAC approval. In systems where the manufacturer issues frequent SB revisions, operators must check ANAC rather than rely solely on Embraer’s portal or documentation.

5. Prohibition on installing the old P/N extends to spares and new installations: Requirement 3 states "LGEU P/N 355-022-002 may not be installed on any aeroplane as either a replacement spare or new installation" and sets the timing as "After 12 September 2011." The ban is not limited to field-installed units; it encompasses spare‑parts usage and new installations. Organisations must therefore adjust procurement and spares policies well in advance of that date to avoid accidental installations.

6. Effective date and date math: The AD states "This Airworthiness Directive becomes effective on 12 March 2009." Given Requirement 1 is within 12 months of that date and Requirement 2 is within 30 months, operators must compute the exact deadline dates from the effective date. Misreading the signature date (27 January 2009) as the effective date or failing to convert months correctly could cause mis-timing of compliance.

7. The AD does not include enforcement or penalty language: Many operators expect ADs to specify consequences for non-compliance. This AD provides deadlines but no enforcement clause in the supplied text. Operators must not infer lack of enforcement; rather they should confirm enforcement procedures with CASA because the AD’s silence on penalties does not mean CASA will not take regulatory action for non-compliance under its broader statutory powers.

8. Cross‑jurisdictional approval dependency: The AD requires ANAC approval for later SB revisions. If ANAC delays approval, operators may be forced to use the original-issue SBs or seek CASA guidance. There is no clause in this AD permitting CASA to accept alternate approvals; operators must anticipate possible timing friction between Embraer, ANAC and CASA.

9. Recordkeeping obligations not specified in this AD: The AD mandates technical replacement "according to the detailed instructions," but does not specify what records should be retained or how to notify CASA. Operators must ensure their own maintenance documentation evidences compliance even though the AD does not set formal documentation procedures.

10. The AD references an ANAC AD "and Errata": The note "ANAC AD 2009-01-01 and Errata refers" suggests there is potentially substantive clarifying information in those documents that could affect the practical scope of the requirements. Failure to consult those items might leave an operator unaware of clarifications or fixes that ANAC issued to its own AD.

Each of these points is grounded in the AD text and affects operational planning. The practical risk is not abstract: misreading applicability, serial-number ranges, SB revision acceptance, or the prohibition timing can cause unplanned grounding, last-minute parts procurement or maintenance bottlenecks.

The AD sets a straightforward set of technical and scheduling requirements. Compliance involves a sequence of verifiable steps that align with the text:

1. Inventory and identification:

   • For each EMB-135 and EMB-145 operated or maintained, inspect maintenance records and the installed unit to confirm whether the Landing Gear Electronic Unit is P/N 355-022-002. The AD’s applicability is P/N-specific: "Applicability: EMB-135 and EMB-145 series aeroplanes equipped with Landing Gear Electronic Unit (LGEU) part number (P/N) 355-022-002."

2. Serial-number determination:

   • For each unit identified as P/N 355-022-002, determine the serial number. If the serial number is "from 1000 to 1999," Requirement 1 applies and the replacement must be scheduled "within the next 12 months after the effective date of this Directive." Since the AD records the effective date as 12 March 2009, the deadline is 12 March 2010. For any other serial numbers of P/N 355-022-002, Requirement 2 applies with a 30‑month window, putting the deadline at 12 September 2011.

3. Obtain the correct service documentation:

   • Acquire the Embraer Service Bulletin(s) named in the AD: SB 145-32-0120 original issue and/or SB 145LEG-32-0032 original issue, "as applicable." The AD allows later revisions only if those later revisions are "approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." Confirm ANAC approval status before relying on a later SB revision.

4. Plan and schedule maintenance:

   • Arrange for the replacement work to be performed "according to the detailed instructions and procedures described in" the specified SB(s). The AD mandates adherence to the SB procedures. Schedule the work within the required compliance window: within 12 months for S/N 1000-1999; within 30 months for all other S/Ns.

5. Replace the unit:

   • Replace LGEU P/N 355-022-002 with LGEU P/N 355-022-003 in accordance with the relevant SB procedures. Ensure maintenance personnel follow the specific procedural steps in the SB that the AD specifies.

6. Prevent future installation of the old unit:

   • After 12 September 2011, do not install LGEU P/N 355-022-002 on any aeroplane, "as either a replacement spare or new installation." Update procurement and spares management policies to block procurement or installation of P/N 355-022-002 after that date.

7. Verification and documentation:

   • While the AD does not set out the exact documentary format, make contemporaneous maintenance records that show the unit replaced, the P/N and S/N of the removed and installed units, the SB issue or ANAC-approved revision used, the date of completion and the certificate or release to service signed by the authorised maintenance certifier. Those records will be the primary evidence of compliance with the AD’s requirements and with the SB-installed procedures.

8. Coordinate approvals where necessary:

   • If intending to use a later SB revision, verify that ANAC has approved that revision. The AD explicitly conditions allowance of later SB revisions on ANAC approval: "or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC)." Keep evidence of ANAC approval together with work records.

9. Check corresponding ANAC AD and errata:

   • The AD includes the note "ANAC AD 2009-01-01 and Errata refers." Operators should obtain and read the referenced ANAC AD and any errata to capture clarifications, additional instructions, or corrections that could affect technical implementation or compliance interpretation.

10. Liaise with CASA for enforcement guidance:

• Because the AD itself does not specify enforcement procedures or penalty provisions, if there is any uncertainty about the acceptability of documentation, deadlines, or the use of a particular SB revision, consult CASA for confirmation on record-keeping, notification procedures, and the treatment of any late compliance. CASA’s administrative practice will determine how compliance is assessed in the absence of specific enforcement language in the AD.

11. Update operational processes:

• Revise maintenance planning, spares inventory and procurement controls to ensure no P/N 355-022-002 units are fitted after the ban date. Notify relevant staff and contractors of the prohibition "After 12 September 2011" to avoid inadvertent non-compliance.

12. Retain evidence of compliance and approvals:

• Preserve copies of the Embraer SB used, any ANAC approval of later SB revisions, and maintenance records reflecting the replacement. These will be the documentary proof required for audits and regulatory review even though the AD does not itself prescribe filing with CASA.

Following these steps will align an operator’s actions with the explicit text of the AD: identify in-scope aircraft and parts, obtain and follow the specified Embraer SBs or ANAC-approved revisions, replace the affected units within the prescribed windows, and ensure no future installation of the banned P/N after the stated date.