AD/ERJ-190/3 Amdt 1 - Flight Guidance Control System

The AD is focused on three core technical and regulatory concepts: applicability by configuration, repetitive monitoring pending a software fix, and termination of the monitoring once a validated software upgrade is installed.

Applicability by configuration. The Directive applies to “All ERJ-190 model aeroplanes equipped with Primus EPIC software load versions 4.3, 4.4, 4.5, 4.6 or 4.7.” That is an equipment- and software-version based scope, not a scope by serial number or operator. The applicability is therefore defined by the installed avionics software load. Operators must therefore identify aircraft by the installed Primus EPIC software load to determine whether the AD applies to a particular aeroplane.

Repetitive monitoring until terminating action. Requirement 1 mandates a functional test of the FGCS channels, performed “in accordance with Embraer Service Bulletin (SB) 190-22-0002, original issue, dated 9 November 2006 or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” The Directive gives a formal definition of the functional check (Note 1): “A quantitative check to determine if one or more functions of an item perform within specified limits.” The compliance timing for this monitoring is specified: carry out the first functional check within the next 300 hours TIS after the effective date of the original issue of the Directive, and thereafter at intervals not exceeding 600 hours TIS until Requirement 2 is accomplished. Requirement 1 is therefore an interim risk-control measure, designed to detect latent failures that would otherwise remain undetected between maintenance events.

Software upgrade as terminating action. Requirement 2 mandates installation of Primus EPIC software load 19.3 in accordance with Embraer SB190-31-0009 (original issue dated 4 May 2007) or a higher software load in accordance with an Embraer SB approved by ANAC. The Directive clarifies that installing 19.3 or higher is “considered a terminating action for the Requirement 1 repetitive functional check” (Note 3). The AD also provides examples of later SBs for higher software versions (SB190-31-0014 dated 5 September 2007 for version 19.4; SB190-31-0015 dated 21 December 2007 for version 21.2), but stresses that any such higher version must be installed under an applicable SB approved by ANAC.

Regulatory linkage. The Directive repeatedly ties actions to ANAC approvals (the Brazilian regulator), and references ANAC AD 2006-11-03R3. The SBs and their revisions are to be those “approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” That creates a compliance chain in which Embraer SB content is adopted subject to foreign regulator approvals, rather than being replaced by independent Australian technical specifications within the text of this AD.

Safety rationale. The Background explains the technical hazard motivating the requirements: some “caution” messages issued by the FGCS were not displayed on aeroplanes with EPIC software loads 4.3-4.7. Consequently, a failure of one FGCS channel could remain undetected and latent; if a second failure then occurred, this could cause an autopilot command hard-over. The AD’s measures are therefore a combination of detection (repetitive functional checks) and remediation (software load upgrade).

Timelines and sequencing. The Directive sets a short-term monitoring schedule (first check within 300 hours TIS, then every 600 hours) and a deadline for the terminating action (Requirement 2). The compliance timing in the document reads “For Requirement 2 - No later than 30 June 2009,” while the Amendment text states it “extends the compliance time for Requirement 2 by one year,” which indicates the AD superseded an earlier, tighter deadline from the original issue. The Amendment itself became effective 18 June 2008; the original issue became effective 27 March 2008.

Documentation and method references. The AD requires maintenance be performed in accordance with particular Embraer SBs (SB190-22-0002 for the test; SB190-31-0009 or other ANAC-approved SBs for the software installation). Operators must use the Embraer-prescribed procedures and the specific dated SB issues or later ANAC-approved revisions mentioned in the Directive.

The Directive’s stated applicability is precise: “All ERJ-190 model aeroplanes equipped with Primus EPIC software load versions 4.3, 4.4, 4.5, 4.6 or 4.7.” That identifies the set of implicated aircraft by model and by installed avionics software load version. Practically, the following parties are affected.

Aircraft operators and owners. Any operator or owner of an ERJ-190 that has one of the specified Primus EPIC software loads is directly within scope. They must implement the functional checks (Requirement 1) on the required schedule, and they must schedule and effect the software installation (Requirement 2) by the Directive’s compliance date. The AD creates recurrent maintenance obligations for as long as the affected software load remains installed.

Maintenance organisations and certifying staff. The required functional test and the software installation must be performed in accordance with Embraer service bulletins (SB190-22-0002 for the functional check; SB190-31-0009 or later ANAC-approved SBs for the software installation). Maintenance organisations will therefore need access to the correct SBs, to ANAC approvals of revisions where applicable, and to personnel authorised to carry out the procedures. Certifying staff must ensure the work matches the SB instructions and that the work is recorded against the aircraft’s TIS to meet the AD’s intervals.

Embraer as design authority and SB issuer. Embraer’s service bulletins are expressly referenced as the method of compliance. Embraer will be a technical partner for operators and maintenance organisations because the SBs contain the procedural detail for the functional test and the software upgrade. The AD also provides examples of later SBs for higher software loads (SB190-31-0014 and SB190-31-0015), so Embraer’s ongoing SB revisions are instrumental to compliance.

Regulators: CASA and ANAC. The AD is published by the Civil Aviation Safety Authority (CASA) Delegate (James Coyne) and references approvals by the Brazilian regulator ANAC. The Directive requires that the referenced SBs be “approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” Therefore compliance depends on ANAC approvals of SB revisions. CASA’s role is issuing the AD and setting compliance in the Australian context; ANAC’s approvals determine which SB revisions are acceptable under this AD.

Operators of aeroplanes not fitted with the specified software loads. If an ERJ-190 has a Primus EPIC software load other than 4.3-4.7 (for example already upgraded to 19.3 or higher), the AD’s applicability language indicates such aircraft are not subject to these requirements. In that respect, the AD imposes no obligations on machines already running an approved terminating software load.

Insurance, scheduling and commercial stakeholders. While not named in the AD, operators’ commercial planning, scheduling and insurance arrangements will be affected because the AD prescribes maintenance intervals (300/600 hours TIS) and a software installation deadline. Those stakeholders will need to coordinate downtime and maintenance resources to meet the AD.

The AD does not specify penalties or enforcement mechanisms in the text provided; it sets the required actions, SB references and compliance dates. The document therefore communicates obligations to the above parties but does not itself include enforcement details or administrative sanction language in its text.

The Directive sets out specific duties and a procedural right to use later ANAC-approved SB revisions. Below are the concrete obligations and the procedural options the AD allows, with the governing references quoted from the text.

Primary duties

• Determine applicability. The operator must determine whether their aeroplane is within scope: “All ERJ-190 model aeroplanes equipped with Primus EPIC software load versions 4.3, 4.4, 4.5, 4.6 or 4.7.” That is the threshold duty before any other action is required.

• Carry out functional testing. Requirement 1: “Carry out a functional test to check the engagement of the Flight Guidance Control System (FGCS) channels in accordance with Embraer Service Bulletin (SB) 190-22-0002, original issue, dated 9 November 2006 or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” The timing duty is explicit: the initial test must be done “within the next 300 hours time in service (TIS) after the effective date of the original issue of this Directive” and thereafter at intervals “that do not exceed 600 hours TIS until Requirement 2 is accomplished.”

• Install software upgrade. Requirement 2: “Install primus EPIC software load 19.3 in accordance with Embraer SB190-31-0009, original issue, dated 4 May 2007 or later revisions approved by the ANAC; or a higher software load version in accordance with an Embraer SB approved by the ANAC.” The compliance date for this installation is stated “No later than 30 June 2009.” The Amendment text also states that it “extends the compliance time for Requirement 2 by one year” relative to the original AD.

• Use proper documentation and approvals. Where a later revision of an SB is relied upon, the SB must be “approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” The Directive lists example later SBs and dates, but it conditions their acceptability on ANAC approval.

Terminating duty and its effect

• Termination of repetitive checks on installation. The AD expressly states that “The installation of the Primus EPIC software load version 19.3 or higher is considered a terminating action for the Requirement 1 repetitive functional check.” That creates a binary transition: the repetitive FGCS tests are required only until the operator installs 19.3 or a higher ANAC-approved software load in accordance with the specified SB.

Procedural rights and options

• Use of later SB revisions. The AD allows compliance either by installing the specified software load (19.3) via SB190-31-0009, or by installing a higher software load “in accordance with an Embraer SB approved by the ANAC.” The Directive gives specific examples of higher versions and associated SBs (19.4 via SB190-31-0014 dated 5 September 2007; 21.2 via SB190-31-0015 dated 21 December 2007), but the operative right is to use any higher version so long as it is installed under an applicable SB that ANAC has approved.

• Definition of a functional check. The Directive provides a definition (“A quantitative check to determine if one or more functions of an item perform within specified limits.”), which constrains the method and evidentiary standard for the tests. Operators must ensure that the tests conducted meet that quantitative standard.

Limits and absences in the AD

• No fines or enforcement mechanisms described. The AD text does not specify civil penalties, criminal sanctions, administrative fine schedules, or an enforcement mechanism within the document itself. It sets mandatory-sounding tasks and deadlines and records an effective date, but the AD does not itself enumerate the legal consequences of non-compliance in the supplied text.

• ANAC linkage. The AD requires reliance on SB revisions “approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” That creates a duty on operators to check the approval status with ANAC for any later SB revision used to comply, rather than allowing reliance on an Embraer SB alone.

Record-keeping and TIS tracking implication

• The AD’s timed compliance (first within 300 hours TIS after the original issue’s effective date, then every 600 hours TIS) imposes a record-keeping duty. Operators must track TIS carefully to meet the intervals and to demonstrate that the terminating action (software installation) occurred before further 600-hour intervals were due. The AD does not detail the form of records that satisfy this requirement, but the timing obligations make accurate TIS records a practical necessity.

The text of the Directive sets technical requirements, SB references and compliance times but does not contain explicit penalty provisions or a description of enforcement proceedings. The AD records who issued it and when (“James Coyne, Delegate of the Civil Aviation Safety Authority” signed 12 June 2008; “This Amendment becomes effective on 18 June 2008”), but the provided document does not articulate the sanctions that follow from non-compliance.

What the AD does provide relevant to enforcement

• Mandatory actions and dates. The AD prescribes Requirement 1 (functional testing) and Requirement 2 (software installation), together with specific compliance timing: initial functional test “within the next 300 hours time in service (TIS) after the effective date of the original issue of this Directive and thereafter at intervals that do not exceed 600 hours TIS until Requirement 2 is accomplished” and Requirement 2 “No later than 30 June 2009.” The presence of explicit duties and deadlines is a factual basis for regulatory enforcement even if the supplied text does not itself set out the enforcement process.

• Delegated authority. The AD is issued and signed by a CASA delegate, which situates the Directive within CASA’s administrative jurisdiction. The AD therefore comes from a recognised civil aviation regulator; the text shows the administrative process for issuing an AD (original issue effective 27 March 2008; Amendment effective 18 June 2008), but it does not transcribe CASA’s enforcement policy or penalty regime.

What the AD does not provide

• No fines, penalties or specified remedies. The supplied text does not include a schedule of fines, civil penalties, or criminal offences for breach, nor does it set out administrative procedures for enforcement (for example, notices, show-cause processes or suspension of operations). The absence is material: operators cannot rely on the AD text alone to know what sanctions might be applied in the event of non-compliance.

• No explicit monitoring or auditing process. The AD mandates testing intervals and installation deadlines, but it does not describe a process by which CASA will audit compliance, request evidence of compliance, or accept compliance records. Similarly, the AD does not describe whether CASA will accept ANAC-approved SB evidence directly or require additional Australian regulatory paperwork.

Interpreting the compliance and enforcement gap

• Practical enforcement implications. Although the AD does not itself set out penalties, the presence of explicit mandatory requirements, SB references and compliance dates creates an expectation of enforcement through normal regulatory channels. In practice, regulators commonly enforce ADs by referencing them in surveillance, audits, and certification processes, and by using broader regulatory instruments to impose sanctions for safety non-compliance. However, the supplied AD text does not specify those mechanisms, so any statement about the actual enforcement procedures, penalties or practice would be beyond what the AD itself records.

• Need for operators to seek clarification. Because the AD does not set out enforcement or administrative remedies, operators and maintenance organisations that require certainty about enforcement consequences or about acceptable evidence of compliance will likely need to consult CASA or their regulatory contact point for clarifications not present in the AD text.

The Directive explicitly references and depends on external technical approvals and prior regulatory actions, but it does not itself cross‑cite Australian statutory provisions within the supplied text. The primary cross-jurisdictional interaction is with the Brazilian regulator ANAC and with Embraer-issued service bulletins.

ANAC approvals are a condition of compliance. The AD repeatedly conditions acceptable methods on ANAC approvals: Requirement 1 testing must follow “SB 190-22-0002, original issue, dated 9 November 2006 or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” Requirement 2 requires installation per “SB190-31-0009, original issue, dated 4 May 2007 or later revisions approved by the ANAC; or a higher software load version in accordance with an Embraer SB approved by the ANAC.” This ties the AD’s acceptable compliance pathways to the decisions of a foreign sovereign regulator (ANAC). The AD also references “ANAC AD 2006-11-03R3 refers” in the notes. The effect is that Australian compliance under this AD requires monitoring ANAC approvals and ADs.

Interaction with Embraer service bulletins. The AD makes Embraer SBs the operative technical method for compliance. It specifies particular SB numbers and issue dates that define how testing and software installation must be done. That places Embraer’s SB programme and its SB revision schedule into the compliance chain for Australian-registered operators. The Directive allows for later SB revisions, but only to the extent those revisions are approved by ANAC.

No Australian regulatory cross-references included. The supplied text does not cite any Australian civil aviation regulations, CASA enforcement provisions, or domestic legal instruments. The AD is issued by CASA (signed by its delegate), but the AD text as provided relies on external ANAC approvals and Embraer SBs rather than restating Australian technical standards or enforcement provisions.

Possible practical interactions

• International regulatory harmonisation. Because the AD depends on ANAC approvals for SB revisions, operators may face mixed regulatory inputs when other authorities (for example, local or other foreign authorities) have separate approval processes. The AD’s requirement that SB revisions be ANAC-approved creates an interaction where ANAC’s decisions materially affect the Australian regulatory obligation in this AD.

• Maintenance approvals and continued airworthiness. The AD’s reliance on Embraer SBs means that maintenance organisations must align their work with the SB procedures. Where an SB calls for particular tooling, software loads, or procedures, those requirements will interact with organisations’ local approvals and capabilities. The AD’s statement that later SBs are allowable provided they are ANAC-approved requires maintenance organisations and operators to verify both the SB content and the ANAC approval status.

• Prior ADs and referenced ANAC AD. The AD explicitly “refers” to ANAC AD 2006-11-03R3. This indicates that there is prior regulatory material relevant to the FGCS and EPIC software loads. Operators should treat the AD as part of an existing chain of regulatory actions and ensure that compliance takes the referenced ANAC AD into account.

Limitations in the supplied text

• No express statement about domestic law hierarchy. The AD does not itself state how it intersects with domestic aviation safety regulations or the administrative powers used to issue it. The absence of express statutory cross-references means that readers must rely on general knowledge of CASA’s powers outside this AD to understand the full legal context; the AD text itself binds readers only to the technical and timing requirements it sets out.

• No guidance on conflicting approvals. The AD does not address what should be done where an SB revision is approved by Embraer and perhaps another authority, but not by ANAC, or where ANAC’s approval status differs from that of other regulators. The operative rule in the AD is ANAC approval, and the AD does not provide an alternate pathway.

The supplied document records a concise chronology of the AD’s original issue and this Amendment, with effective dates and the stated changes effected by the Amendment.

Original issue. The background states “The original issue of this Directive became effective on 27 March 2008.” That original AD required repetitive functional testing of the FGCS pending installation of a corrected software load. The original AD was prompted by ANAC reports that some FGCS caution messages were not displayed under certain EPIC software loads, which created a latent-failure risk.

Amendment Amdt 1. The current document is titled “AD/ERJ-190/3 Amdt 1” and is dated and signed on 12 June 2008 by James Coyne, Delegate of the Civil Aviation Safety Authority. The Amendment is recorded as effective on 18 June 2008 (“This Amendment becomes effective on 18 June 2008.”). The Amendment’s stated content changes are: it “continues the repetitive testing of the FGCS and extends the compliance time for Requirement 2 by one year,” and it “clarifies how higher versions of the software load may be installed.” The Amendment therefore does not remove the Requirement 1 repetitive tests; rather it maintains that interim testing regime and lengthens the period allowed to carry out Requirement 2.

Compliance dates in the text. The Compliance block in the Amendment records the timing obligations. For Requirement 1 it states the intervals (first within 300 hours TIS after the effective date of the original issue, then at intervals not exceeding 600 hours until Requirement 2 is accomplished). For Requirement 2 it states “No later than 30 June 2009.” Taken together with the Amendment’s textual statement that it “extends the compliance time for Requirement 2 by one year,” the Amendment appears to have replaced or lengthened an earlier, sooner deadline that was in the original issue. The Amendment also clarifies acceptable higher software versions by referencing additional Embraer SB numbers and dates (for example SB190-31-0014 and SB190-31-0015).

References to ANAC AD. The Amendment notes “ANAC AD 2006-11-03R3 refers,” indicating there is a prior ANAC AD relevant to the safety issue. The Amendment conditions acceptability of SB revisions on ANAC approvals, thereby integrating that foreign regulator’s materials into the Amendment’s compliance framework.

Signature and administrative record. The document bears a delegate’s signature (James Coyne) and a printed date (12 June 2008), which is the administrative sign-off preceding the Amendment’s effective date of 18 June 2008. The Amendment thus provides a short administrative trace: original AD effective 27 March 2008; Amendment signed 12 June 2008; Amendment effective 18 June 2008.

No further amendments in the supplied text. The provided material includes only the original issue and this first Amendment (Amdt 1). The AD’s text lists specific SBs and ANAC approvals that operators must rely on; it does not provide a subsequent amendment log or later changes beyond Amdt 1 within the supplied document.

The supplied Directive contains no litigation history, no citations to judicial decisions, and makes no mention of disputes, appeals, or legal challenges to the AD or to Embraer’s SBs. The document is purely regulatory and technical in character and records only the AD content, the SB references, the ANAC approvals requirement, the effective dates, and the signature of the CASA delegate.

What the supply of no litigation history implies in practice

• No recorded challenges within the AD text. There is nothing in the AD that indicates litigation has occurred, nor are there references to court cases, arbitration, or administrative appeals. The AD does not include a statement of rights of review or appeal within the text provided.

• Operators seeking legal certainty. For operators who wish to know whether this AD has been the subject of legal dispute or interpretation by courts or tribunals, the supplied AD does not provide that information. They would need to consult external legal databases or CASA records for any subsequent litigation or appeals that might have tested the AD’s scope or enforcement.

• Technical, not legal, focus. The absence of litigation references is consistent with the AD’s technical purpose: to prescribe maintenance and software changes to address a specific FGCS display/failure hazard. The AD text focuses on procedural compliance with SBs and ANAC approvals rather than on legal process or dispute resolution.

Therefore, based on the supplied material alone, there is no litigation history to report. Any assertion about subsequent legal challenges, clarifications, or judicial treatment would require sources outside the AD text provided.

The Directive’s precision and cross‑references create several practical traps for operators, maintainers and certifying staff. Below are the concrete “gotchas” that arise from close reading of the AD text.

Applicability is version-specific, not aircraft-specific. The AD applies to “All ERJ-190 model aeroplanes equipped with Primus EPIC software load versions 4.3, 4.4, 4.5, 4.6 or 4.7.” That means an ERJ-190 with a different Primus EPIC load is outside scope; conversely, even a single aircraft with the old software is in scope regardless of owner. Operators must not assume fleet-wide applicability; they must check the exact installed software version on each aeroplane.

Timing language links to the original issue’s effective date. Requirement 1’s initial test is “within the next 300 hours time in service (TIS) after the effective date of the original issue of this Directive,” and the original issue became effective on 27 March 2008. Operators must read the timing in light of that effective date and calculate TIS accordingly. Confusion may arise because the Amendment is effective 18 June 2008 and also says it “extends the compliance time for Requirement 2 by one year.” Ensure you use the correct reference point for the 300-hour initial test (the original issue’s effective date) versus the Amendment’s effective date.

Concurrent obligations until terminating action. The AD requires repetitive FGCS tests until the software installation is completed. Installing the software load 19.3 or higher is “considered a terminating action for the Requirement 1 repetitive functional check.” Operators who delay the software upgrade must ensure they actually perform the 600-hour interval tests without fail; missing tests could leave the aircraft subject to latent failures that the AD is intended to detect.

ANAC approvals are required for later SB revisions. The Directive allows later SB revisions and higher software loads only if they are “approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).” This means that installing an Embraer SB revision that is not ANAC‑approved will not satisfy the AD. Operators must verify the ANAC approval status of the specific SB revision they intend to use.

Examples do not equal exclusivity. The AD gives examples of higher versions and their SBs (for example, version 19.4 via SB190-31-0014, dated 5 September 2007; version 21.2 via SB190-31-0015, dated 21 December 2007), but the operative requirement is to install 19.3 or “a higher software load version in accordance with an Embraer SB approved by the ANAC.” Do not assume that the only acceptable higher versions are those examples , acceptability depends on ANAC approval of the relevant SB.

Ambiguous compliance-date language in the Amendment text. The Compliance block states Requirement 2 is “No later than 30 June 2009,” while the Amendment text mentions it “extends the compliance time for Requirement 2 by one year.” Care is needed to reconcile the original AD’s deadline and the Amendment’s extension: confirm the date that is operative for your aircraft and whether any earlier deadlines applied that the Amendment replaced.

Functional check definition is quantitative. Note 1 defines a functional check as “A quantitative check to determine if one or more functions of an item perform within specified limits.” That requires the test performed under SB190-22-0002 to produce quantitative results within specified limits, not merely a qualitative or cursory verification. Ensure maintenance procedures and certifying staff document quantitative outcomes against the SB’s specified limits.

No enforcement detail in the AD text. The AD does not set out penalties or the enforcement process. That absence is a regulatory “gotcha”: operators cannot infer enforcement procedures or penalties from this document and should seek confirmation from CASA if enforcement consequences are material to compliance decisions.

Record-keeping and TIS tracking must be precise. The AD’s time-based intervals (300/600 hours TIS) demand accurate tracking of TIS. A miscalculation or poor records could lead to missed tests, leaving the aircraft in a state the AD intends to avoid.

Interplay with local approvals or other regulator decisions. Because the AD makes ANAC approvals dispositive for SB revisions, operators who rely on other regulators’ approvals or on local engineering approvals must confirm ANAC status before relying on the SB for compliance under this AD.

This section sets out practical steps, tracing the AD’s textual requirements to concrete actions operators and maintenance organisations should follow, citing the exact references provided in the AD.

1. Confirm applicability per installed software load

   • Inspect each ERJ-190 to confirm the installed Primus EPIC software load. The AD applies only to aircraft “equipped with Primus EPIC software load versions 4.3, 4.4, 4.5, 4.6 or 4.7.” If your aircraft has 19.3 or higher already installed, the AD’s Requirements 1 and 2 will not apply as the installation of 19.3+ is a terminating action for the repetitive test.

2. Schedule and perform Requirement 1 functional test

   • Perform the FGCS functional test “in accordance with Embraer Service Bulletin (SB) 190-22-0002, original issue, dated 9 November 2006 or later revisions approved by the Brazilian Agência Nacional de Aviação Civil (ANAC).”
   • Timing: carry out the first functional check within the next 300 hours TIS after the effective date of the original issue of the Directive (original issue effective 27 March 2008). Thereafter, perform the test at intervals not exceeding 600 hours TIS until Requirement 2 is completed.
   • Ensure the functional check meets the AD’s quantitative definition: Note 1 defines a functional check as “A quantitative check to determine if one or more functions of an item perform within specified limits.” Record quantitative results and retain test records to demonstrate compliance with the 600-hour interval schedule.

3. Arrange for Requirement 2 software installation before the compliance deadline

   • Install Primus EPIC software load 19.3 in accordance with Embraer SB190-31-0009 (original issue dated 4 May 2007) or install a higher software load in accordance with an Embraer SB approved by ANAC.
   • Confirm the specific SB revision you will use is approved by ANAC: the AD conditions acceptability on ANAC approval.
   • Note examples: the AD cites SB190-31-0014 dated 5 September 2007 for version 19.4 and SB190-31-0015 dated 21 December 2007 for version 21.2 as examples of higher versions. If you plan to use a higher version, ensure the corresponding SB is ANAC‑approved and follows the AD’s procedural instructions.

4. Use the software installation as a terminating action for the repetitive testing

   • Once 19.3 or a higher ANAC-approved software load is installed in accordance with the AD, the Directive says “The installation of the Primus EPIC software load version 19.3 or higher is considered a terminating action for the Requirement 1 repetitive functional check.” Update maintenance programmes and records accordingly to cease the 600-hour repetitive checks for that aircraft.

5. Maintain records and track TIS rigorously

   • The AD’s compliance cycles are expressed in hours TIS: initial test within 300 hours after the original issue’s effective date and subsequent tests every 600 hours until the software upgrade is done. Operators must maintain accurate TIS logs and store quantitative functional test results. Retain documentation of software installation performed under the specified SB and evidence of the SB’s ANAC approval.

6. Coordinate with Embraer and authorised maintenance organisations

   • Perform the functional test and software installation under Embraer-prescribed procedures and ensure maintenance staff are authorised under relevant approvals. For software installation, confirm any tooling, loading procedures and verification steps in the applicable SB.

7. Verify ANAC approvals and cross-reference ANAC AD 2006-11-03R3

   • The AD refers to ANAC AD 2006-11-03R3. Check that ANAC AD and any ANAC approvals referenced by the SBs are current and apply to your intended SB revision. If there is uncertainty about ANAC approvals, contact Embraer or ANAC for confirmation before undertaking compliance actions.

8. Plan maintenance windows for downtime and resource allocation

   • The AD creates a scheduling burden: repetitive testing until the software upgrade is done, and a software installation deadline (stated in the AD as “No later than 30 June 2009,” with the Amendment noting it “extends the compliance time for Requirement 2 by one year” relative to the original AD). Plan maintenance slots, software licences/loads and qualified engineers to meet the deadline.

9. Seek regulatory clarification where needed

   • The AD does not specify enforcement mechanisms or penalty regimes within the text provided. If you require confirmation about acceptable evidence of compliance, the administrative process for recording compliance, or potential enforcement consequences, contact CASA for guidance. Also seek clarification if there are any conflicts between ANAC approvals and other regulatory approvals you hold.

10. Document the transition from testing to termination

    • After installation, document that the software install was performed under the specified Embraer SB and that the SB revision used was ANAC-approved. Record the date and TIS at installation and archive the functional test history up to that point; use those records to justify cessation of the 600-hour repetitive checks for that aircraft.

Follow the AD’s precise text when implementing. The Directive ties compliance to specific Embraer SB numbers and issue dates and conditions acceptability on ANAC approvals. Use the exact SBs and ANAC approvals referenced, and retain documentation of the tests and the software installation to demonstrate compliance with the AD’s timing and procedural requirements.