AD/ERJ-170/3 Amdt 1 - Air Data Smart Probes

The directive rests on a compact set of technical and regulatory concepts articulated in the text. Applicability is narrow and technical: it applies to ERJ-170( ) model aeroplanes that are equipped with air data smart probes having part numbers P/N 2015G2H2H-4( ), 2015G2H2H-5( ), 2015G2H2H-6( ) or 2015G2H2H-7( ) (Applicability). The hazard is operational: moisture ingress into the pneumatic passage from the pitot port to the pressure sensors in the probes, which may freeze and block the sensors, generating erroneous air data inputs to the aircraft systems (Background). The mandated technical remedy is inspection and moisture removal per a manufacturer service bulletin: Embraer SB 170-34-0007 original issue dated 28 April 2005 or later ANAC-approved revisions (Requirement 1). The directive supplies a formal definition of "detailed inspection" for the purposes of the requirement, taken from the directive text: it is an intensive examination potentially requiring supplementary lighting, mirrors, magnifying lenses, surface cleaning and elaborate access procedures (Note 1). A replacement pathway is specified: optional installation of probe P/N 2015G2H2H-8 in accordance with SB 170-34-0018, original issue dated 19 September 2006 or further ANAC-approved revisions, constitutes terminal action to the repetitive inspections (Requirement 1, optional terminal action). The directive also introduces a prohibitory rule: as of the amendment’s effective date, older probe P/Ns 2015G2H2H-4/5/6/7 may not be reinstalled on any aeroplane as a replacement for probe P/N 2015G2H2H-8 (Requirement 2). The compliance cadence is instrumented by time-in-service metrics: initial compliance within 600 hours TIS tied either to the first Australian Certificate of Airworthiness or to the last inspection under the original AD, and recurring inspections at intervals not exceeding 600 hours TIS thereafter (Compliance). Approval of SB revisions by ANAC is invoked repeatedly, creating an explicit dependence on another regulator for acceptance of later SB revisions as compliant means of meeting the AD obligations. The document’s provenance and legal force are signalled by the CASA delegate’s signature, the Amendment number, and effective date.

The immediate, explicit addressees are operators and maintainers of Embraer ERJ-170 series aeroplanes that have the listed air data smart probe part numbers installed (Applicability). The directive applies only to ERJ-170( ) model aeroplanes equipped with probes P/N 2015G2H2H-4( ), -5( ), -6( ) or -7( ), so aircraft without those part numbers are not within the stated scope. The operators holding or applying for an Australian Certificate of Airworthiness for affected aeroplanes are directly implicated, because the inspection timing references that certificate and the directive becomes effective in the Australian regulatory environment. Maintenance organisations engaged to carry out the "detailed inspection" and cleaning will be operationally affected, because the inspection definition in Note 1 expressly contemplates use of inspection aids, surface cleaning, and "elaborate access procedures." Those services impose labour, tooling and access costs on the entity that performs the work. Parts suppliers and inventory managers will be affected by the prohibition in Requirement 2 which prevents older probe P/Ns from being reinstalled as replacements for probe P/N 2015G2H2H-8; procurement, stockholding and spare parts strategies will need to reflect the prohibition and the optional terminal action of installing P/N 8. The manufacturer (Embraer) is relevant because the directive explicitly relies on Embraer service bulletins as the technical means to comply, and because the optional terminal action is installation of a manufacturer-specified probe and installation procedures (SB 170-34-0018). Regulatory authorities beyond CASA have a stake: the text repeatedly conditions acceptability of later SB revisions on approval by the Brazilian ANAC, and it references an ANAC AD (ANAC AD 2006-05-05R1), indicating cross-jurisdictional regulatory interaction where ANAC approvals determine which SB revisions satisfy the AD. Finally, flight operations and safety managers are affected because the stated hazard is erroneous air data indications to the Air Data System; while the directive does not quantify operational risk, those responsible for flight safety must incorporate the inspection cadence and any pending probe replacements into dispatch and maintenance planning. The directive’s effective date and amendment history create deadlines and retrospective application windows that operators must track against each aircraft’s TIS and last inspection history.

The primary duty imposed is a maintenance duty to perform a "detailed inspection" of each aeroplane’s four air data smart probe drain holes and to remove any accumulated moisture when found. The directive prescribes both the mandatory technical standard for the inspection (Emb­raer SB 170-34-0007 original issue dated 28 April 2005 or later ANAC-approved revisions) and a detailed operational definition of the inspection itself (Note 1). Operators must perform the first inspection within either 600 hours TIS after the first issue of an Australian Certificate of Airworthiness, or within 600 hours TIS after the last inspection conducted under the original issue of this Directive, whichever occurs first, and then repeat at intervals not exceeding 600 hours TIS until the probe is replaced by P/N 2015G2H2H-8 (Compliance). A complementary duty follows from Requirement 2, which prohibits reinstallation of older probe P/Ns 2015G2H2H-4/5/6/7 as replacements for probe P/N 2015G2H2H-8 on any aeroplane as of the amendment’s effective date. Operators therefore have a duty not to install those older parts where they would serve as replacements for P/N 8. The directive grants a procedural right of termination: operators have the option to install probe P/N 2015G2H2H-8 in accordance with Embraer SB 170-34-0018 (original issue dated 19 September 2006 or later ANAC-approved revisions), and such installation constitutes terminal action to the repetitive inspection requirement. The directive also implicitly allows reliance on later SB revisions, provided those revisions are approved by ANAC. That creates a regulatory right for operators to comply with subsequent, ANAC-approved SB revisions rather than strictly the original issue documents. The document does not set out administrative appeal mechanisms, penalty schedules, or variance procedures within the text itself. The effective date and the stated signature by the CASA delegate make the duties operative from 4 April 2008. The directive therefore imposes affirmative, recurrent maintenance obligations, prohibits certain replacement parts in a particular substitution context, and offers a one-time equipment replacement pathway to remove the recurring inspection burden, conditioned on compliance with manufacturer SBs and ANAC approvals.

The directive text identifies the Civil Aviation Safety Authority as the issuing authority via the signature of its delegate, David Punshon, and specifies an effective date for the Amendment of 4 April 2008. The instrument sets binding technical compliance obligations with precise time-in-service intervals for inspection and removal of moisture, and a categorical prohibition on reinstallation of certain probe P/Ns as replacements for P/N 2015G2H2H-8. The document itself does not itemise civil or criminal penalties, nor does it reproduce administrative enforcement procedures or sanctioning clauses. The compliance obligations are expressed in mandatory language and framed as airworthiness directives, that is, instrumented requirements for continued safe operation of the aeroplane. Enforcement therefore arises from the regulator’s authority to set airworthiness conditions, including the interrelationship with the Australian Certificate of Airworthiness referenced in the compliance timing; the Directive ties inspection timing to that certificate and to prior inspections performed under the original issue, establishing a compliance metric that regulators can verify against maintenance records and Certificate of Airworthiness status. The directive references Embraer service bulletins and ANAC approvals as the required standards and approvals for compliance, thereby giving regulators an evidentiary basis to determine whether an operator met the required inspection and replacement standards. The document does not specify who bears administrative costs such as oversight audits, nor does it specify a process for seeking exemptions or alternative means of compliance within the text provided. The absence of explicit penalty language in the text means any enforcement response would be governed by the wider statutory and regulatory framework that authorises CASA to oversee airworthiness and to enforce compliance; that wider framework is not set out in this directive itself. Practically, the directive sets measurable duties and timeframes which can be audited against maintenance logs, part numbers installed, and records of SB compliance and approvals.

The directive expressly incorporates and depends on material and approvals external to the instrument itself. It requires compliance with Embraer Service Bulletins as the technical standard for inspections and for the terminal action of installing a replacement probe. Those SBs are accepted only when they are the original issues dated in the directive or when they have been further revised and those revisions have been approved by the Brazilian Agência Nacional de Aviação Civil (ANAC). The directive therefore establishes an inter-regulatory dependency where an Australian civil aviation directive accepts ANAC’s approval of manufacturer SB revisions as determinative for compliance. The text also references an ANAC airworthiness directive by identifier, ANAC AD 2006-05-05R1, indicating that the matter has been the subject of parallel direction by the Brazilian regulator. The directive ties its inspection timing to the Australian Certificate of Airworthiness; an operator must determine the relevant 600 hours TIS window either from the issuance of that certificate or the last inspection carried out under the prior AD. This creates an operational interface between the AD’s obligations and the administrative lifecycle of the Australian Certificate of Airworthiness. The directive does not amend or reproduce broader statutory provisions, enforcement mechanisms, or appeal routes that might exist in aviation law; those remain outside the text. It also does not purport to grant or remove rights under other statutes; rather, it operates as a technical airworthiness requirement that will be enforced in the context of the broader aviation regulatory system. In practical terms, compliance requires alignment among manufacturer instructions (SBs), foreign regulator approvals (ANAC), and Australian regulatory administration (CASA’s AD and Certificate of Airworthiness framework). The directive thereby creates a compliance pathway that crosses manufacturer documentation and two national regulators.

The document is explicitly an Amendment 1 to AD/ERJ-170/3, identified in the heading "AD/ERJ-170/3 Amdt 1" and dated 4/2008 DM. The Amendment becomes effective on 4 April 2008. The text records that the original issue of the Directive became effective on 4 April 2007. The Amendment continues the repetitive inspection requirement from the original issue until an optional replacement probe (P/N 2015G2H2H-8) is installed, and it adds or reiterates the prohibition against reinstalling older probe P/Ns as replacements for P/N 2015G2H2H-8 from the Amendment’s effective date. The directive notes that ANAC AD 2006-05-05R1 is related, and it cites the dates of Embraer service bulletins that are the technical bases: SB 170-34-0007 original issue dated 28 April 2005, and SB 170-34-0018 original issue dated 19 September 2006. The Amendment therefore formalises an ongoing safety management step that began with an original AD effective in April 2007, and it records the chain of manufacturer SBs and ANAC AD references that underpin technical compliance. The signature block is dated 26 February 2008 and signed by David Punshon, Delegate of the Civil Aviation Safety Authority, which indicates the administrative act of amendment was signed prior to the effective date. The text does not list prior amendments other than indicating this is an amendment to the original AD; there is no schedule of earlier revisions within the document beyond the original issue. The directive also incorporates the possibility of later SB revisions being accepted, provided those revisions are approved by ANAC, which creates a mechanism by which future manufacturer updates can be assimilated into the AD without further amendment by CASA, contingent on ANAC approval.

The directive text contains no litigation history and does not reference any judicial or administrative proceedings challenging the AD or its earlier iteration. The only other regulatory document cited is ANAC AD 2006-05-05R1. There is therefore no case law, appeal decision, or court order recorded within the instrument. If litigation has occurred outside the document, it is not reflected in the text provided. The document is an administrative safety direction issued by the Civil Aviation Safety Authority delegate and sets technical obligations, but it does not include any account of disputes, challenges, or adjudications related to the directive, its requirements, or its application. For the purposes of assessing legal risk or precedent, practitioners must note that the directive does not furnish any examples of contested enforcement, nor does it provide information on administrative review or appeal outcomes. The absence of litigation entries in the text means the only legal record available in this instrument is the directive itself, its stated effective dates, the SBs and ANAC AD it references, and the signature of the CASA delegate.

There are several operational and administrative pitfalls that are explicit in the directive text, and a few that follow as direct consequences of the structure of the obligations. First, the inspection is defined as a "detailed inspection" with an expansive operational description: it may require supplementary lighting at appropriate intensity, inspection aids such as mirrors and magnifying lenses, surface cleaning and elaborate access procedures (Note 1). That means the inspection is not a quick visual check; it may require disassembly, specialised tools and additional manpower, which increases downtime and cost implications beyond a simple line check. Second, the compliance timing is framed in terms of hours time in service. The initial inspection must be carried out either within the next 600 hours TIS after the first issue of an Australian Certificate of Airworthiness, or within 600 hours TIS after the last inspection performed under the original issue of the Directive, whichever occurs first. Operators must therefore be precise about each aeroplane’s TIS, the date of the Australian Certificate of Airworthiness issuance, and whether prior inspections under the original AD have already occurred; small recordkeeping errors could lead to non-compliance. Third, the directive makes the optional replacement with probe P/N 2015G2H2H-8 the "terminal action" to stop the repeat inspections, but it conditions acceptable installation on adherence to Embraer SB 170-34-0018 or ANAC-approved subsequent revisions. That means operators wishing to stop the recurring inspections must obtain and follow the correct SB revision and ensure any later revision is ANAC-approved. Fourth, Requirement 2 prohibits reinstalling older probe P/Ns as replacements for probe P/N 8 as of the amendment’s effective date, which can be operationally surprising: it does not merely ban older P/Ns in general, it bans their use as replacements for P/N 8, so part-use scenarios and stock rotation must be carefully managed to avoid installing a forbidden substitution. Fifth, the directive references ANAC approvals for SB revisions; reliance on ANAC approvals introduces a cross-jurisdictional dependency that may complicate procurement or engineering change control if ANAC has not approved the particular SB revision an operator intends to use. Sixth, the instrument does not set out variance, appeal or exception mechanisms in the text, nor does it specify enforcement sanctions; operators needing relief or clarification will need to approach CASA through the regulator’s usual channels, which are not described in the document. Finally, the instrument is quite prescriptive about part numbers; accurate identification of installed air data smart probe P/Ns is essential, and misidentification could lead to unnecessary inspections or an inadvertent breach of Requirement 2.

Step 1, identify affected aeroplanes and parts. Verify for each ERJ-170 in the Australian registry whether it is equipped with air data smart probes P/N 2015G2H2H-4, -5, -6 or -7, as the AD applies only to aeroplanes equipped with those specific part numbers (Applicability). Check maintenance and parts records to confirm installed part numbers and the last date and TIS of any prior inspections performed under the original issue of the Directive. Step 2, schedule the initial detailed inspection. For each affected aeroplane, schedule a detailed inspection of the four probe drain holes in accordance with Embraer SB 170-34-0007, original issue dated 28 April 2005, or with a later revision only if that revision has ANAC approval. Ensure the inspection is performed within the earlier of these two windows: 600 hours TIS after the first issue of an Australian Certificate of Airworthiness for that aeroplane, or 600 hours TIS after the last inspection that was performed under the original issue of this Directive (Compliance). Step 3, prepare for a "detailed inspection." The directive’s Note 1 defines the inspection as intensive, likely to require supplementary lighting, inspection aids such as mirrors and magnifying lenses, surface cleaning and possibly elaborate access procedures. Ensure maintenance personnel have the SB procedures, required access equipment, and clearance to perform surface cleaning and any necessary access tasks. Document the inspection method and outcomes per the SB and regulatory recordkeeping practices. Step 4, remediate findings. If moisture is found, remove accumulated moisture in accordance with the SB’s procedures. Maintain records of moisture findings, actions taken, and any part replacements or repairs. Step 5, manage recurring inspections. Arrange recurring inspections at intervals not exceeding 600 hours TIS until the probe is replaced by P/N 2015G2H2H-8. Track hours in service meticulously to ensure inspections occur before the 600 hours TIS limit. Step 6, consider terminal action. If an operator elects to eliminate the recurring inspection obligation for an aeroplane, arrange for installation of probe P/N 2015G2H2H-8 in accordance with Embraer SB 170-34-0018, original issue dated 19 September 2006, or a later revision only if that revision has been approved by ANAC. Confirm that the installation is performed per the SB and obtain any necessary logbook entries or Certificate of Release to Service documentation. Step 7, avoid prohibited substitutions. As of the amendment’s effective date, do not reinstall probes P/N 2015G2H2H-4, -5, -6 or -7 on any aeroplane as replacements for probe P/N 2015G2H2H-8. Implement spare parts controls and maintenance planning to prevent inadvertent installation of those older P/Ns in substitution contexts. Step 8, recordkeeping and evidence. Maintain maintenance records showing compliance with the SBs and the AD’s intervals, the TIS at which inspections were performed, any moisture removal actions, and any installations of P/N 2015G2H2H-8. Ensure records are available for audit against the Australian Certificate of Airworthiness. Step 9, liaison with regulators and manufacturer. If relying on later SB revisions, verify and document ANAC approval for the specific revision relied upon. Where there is uncertainty regarding interpretation, seek clarification from CASA through its normal channels, quoting the AD identifier AD/ERJ-170/3 Amdt 1 and the relevant SB references. The directive’s signatory and dates are David Punshon, Delegate of the Civil Aviation Safety Authority, dated 26 February 2008, with the Amendment effective 4 April 2008; ensure compliance planning takes those dates into account when interpreting retrospectivity and scheduling inspections.