Several aspects of AD/F100/91 Amdt 1 can trap the unwary operator, maintainer, or compliance manager.
Dual compliance paths and the risk of doing the job twice. For aeroplanes in pre‑SBF100‑28‑046 configuration, the AD offers two choices: Requirement 1a (install P/N 53‑0013 per the older bulletin) or Requirement 1b (install P/N 53‑0027 per the newer bulletin). An operator who chooses 1a will then later have to accomplish Requirement 2 (replace P/N 53‑0013 with P/N 53‑0027) within 18 months of 30 July 2009. That means performing the same job twice on the same valve, incurring double labour, parts, and downtime. Requirement 1b is clearly the better economic choice, as it goes directly to the final approved part. However, an operator who already complied with Requirement 1a (perhaps before the amendment issued) is forced to do the second replacement. There is no credit for early compliance; the amendment is retroactive in effect for those who followed the earlier mandate.
Compliance date snarls for Requirement 1. The compliance time for Requirement 1 is “within 12 months from 28 August 2008”. The amendment effective date is 30 July 2009, which is only about a month before the 12‑month deadline. An operator who had not yet complied by the amendment date would have had only four weeks to source the parts and accomplish either 1a or 1b. Since 1b requires the newer actuator P/N 53‑0027, which may not have been as readily available in early‑mid 2009, the operator might have been forced into 1a (the temporary fix) and then later 2. Operators must be aware that the original deadline was not extended.
The prohibition after 12 December 2010 applies to installation only. Requirement 3 says “Do not install a P/N 53‑0013 fuel crossfeed valve actuator on any aeroplane” after that date. It does not say that existing installations of P/N 53‑0013 are immediately banned. Rather, those existing installations must be removed and replaced with P/N 53‑0027 within the 18 months for Requirement 2. If an operator replaces an actuator after 12 December 2010, it cannot use P/N 53‑0013. But even before that date, using P/N 53‑0013 in a new installation is only permitted if the aeroplane is pre‑configuration and the operator chooses path 1a. However, doing so would then trigger Requirement 2 anyway. So, practically, after the amendment, there is little reason to ever install P/N 53‑0013.
Note 1 relief is conditional. Note 1 provides that after installing P/N 53‑0013 or P/N 53‑0027, the requirements of AD/F100/84 no longer apply “to the fuel crossfeed valve actuators installed on that aeroplane.” This suggests that AD/F100/84 may also impose requirements on other parts of the fuel crossfeed system (e.g., pipes, mounting blocks, or the valve body itself). An operator cannot assume the entire AD is discharged; only the actuator portion is relieved. The exact wording of AD/F100/84 must be checked.
Permissive use of later approved revisions. The AD states that “the use of later approved revisions of these documents is acceptable for compliance.” This means an operator should check whether Fokker Services has issued Revision A, B, etc., of SBF100‑28‑046 or SBF100‑28‑061. Using the original issue of the bulletin may be acceptable, but if a revision corrects an error or adds a caution, the operator may be better off using the latest version. However, the operator must ensure that the revision is approved (typically by Fokker and accepted by CASA). If the bulletin is revised to require a different part number, the operator would need to ensure that still satisfies the AD.
Interaction with AD/F100/84. As noted, the relief from AD/F100/84 only applies after installation of the new actuators. For aeroplanes still in pre‑SBF100‑28‑046 configuration with P/N 9409122, all requirements of AD/F100/84 remain in full force. Operators must not assume that complying with this AD automatically lifts all preventive requirements; the relief is specific.
No explicit alternative means of compliance (AMOC). The AD does not mention AMOCs. While CASR Part 39 generally allows CASA to approve an AMOC, the source does not provide that right explicitly. Operators seeking to use a different method or part must apply to CASA separately. Relying on an AMOC without prior approval could be found non‑compliant.
Effective date confusion. The original AD had an effective date of 28 August 2008. The amendment effective date is 30 July 2009. The compliance times for Requirement 2 are measured from “the effective date of this AD” - which refers to the amendment effective date (30 July 2009), not the original date. For Requirement 1, it refers to “the effective date of the original issue of this AD” (28 August 2008). Operators must read carefully to avoid applying the wrong base date.