The Directive contains a number of practical traps and detailed requirements that can give rise to inadvertent non-compliance if overlooked. These are specific and grounded in the Directive’s text.
Serial-number list is the defining criterion. Applicability depends on serial numbers listed in SB 601-00006-096 Revision 1. Note 1 states that the serial numbers listed in that Revision 1 are identical to those listed in AD/INST/56 and AD/INST/56 Amdt 1 except that PFDs subsequently serviced under an FAA-approved AMOC have been omitted. That means an affected unit might be excluded from the serial-number list because of an FAA-approved AMOC. Operators must ensure they refer to the exact revision of SB and to AMOC records, because an apparently affected serial number could in practice be compliant if an FAA AMOC applies.
Records versus physical inspection. Requirement 1 allows reliance on maintenance records if they positively identify that the installed PFD is not an affected serial number. However the Directive contemplates the common situation where records are incomplete or ambiguous and then requires visually inspecting the PFD in Requirement 2. Operators should be careful with identification: the PFD serial number location and the requirement to inspect for factory markings (“Deviation 08-19A” or “MOD 52”) near the TSO label per SB Section 3.2 are precise. Misreading or failing to locate the correct label could lead to unnecessary further actions or, conversely, missed non-compliance.
Who can sign. Note 3 and Note 5 allow the registered operator/owner to carry out the Requirement 1 determination and to insert limitations into AFM/POH/AFMS or maintenance records and fabricate the placard, provided they hold at least a private pilot’s licence and make an entry in the aircraft records. The gotcha is that an owner without a private pilot’s licence cannot perform those self-certification tasks; such an owner would need a maintenance organisation or another appropriately licensed person to make the entry and effect the insertions. Similarly, the owner must ensure the record entry is properly made, as it is the documentary proof of compliance.
Placard and AFM insertion specifics. For aircraft without AFM/POH/AFMS the Directive requires both inserting the Appendix into the aircraft maintenance records and fabricating a placard with a specified text and minimum letter size of 3 mm. Failure to install the placard or to record the Appendix properly creates a gap in compliance that may be revealed at inspection. The required placard text is not free-form; Requirement 3.a.ii(B) gives a precise wording that must be used.
Timing pressure. The five-day and 15-day deadlines are short. Requirements 1, 2 and 3.a must be done within five days of the effective date, with tests and remedial actions required within 15 days. Operators with multiple aircraft or with airframes away from main bases might find logistics and maintenance scheduling challenging. Requirement 4’s installation prohibition is effective immediately after the Amendment’s date; any PFD procurement or replacement after that date must ensure the unit has either been modified or tested.
Verification test protocol. The Directive requires the air data system performance verification test described in SB Section 3.3 where the factory modification marking is not present. That test must be performed correctly and documented. Operators should ensure the maintenance organisation conducting the test follows SB Section 3.3 exactly, otherwise a marginal or improperly recorded test could be challenged. The Directive does not itself specify who must perform the test, but the complexity of the test could make an appropriately authorised maintenance organisation the practical choice.
Removal and replacement cost. Requirement 3.d(i) requires removal and installation of a PFD that has passed the verification test, has been factory modified, or is not one of the affected serial-number PFDs. That creates a direct cost implication where a unit fails the test. Replacement parts, downtime and labour may be material for some operators. There is no funding mechanism or grace period described in the Directive. The operator must therefore budget for potential replacement or factory modification.
Parts market friction. Requirement 4 effectively constrains the pool of available replacement PFDs by prohibiting installation of affected serial-number units unless they pass the test or have the factory modification mark. In a thin domestic market for those parts, operators may face difficulty sourcing compliant replacement units rapidly.
Cross-jurisdictional AMOC dependence. The Directive’s acceptability of FAA AMOCs is a double-edged sword. It allows reliance on FAA approvals, but operators must ensure that the FAA AMOC precisely covers their particular serial-number unit and installation; otherwise the serial number may remain covered by the Directive. Misreading AMOC applicability may lead to inadvertent non-compliance.
Appendix operational prohibitions. The Appendix includes explicit operational prohibitions, including that flight under IFR or in conditions where horizon reference is unreliable must not be initiated or continued if the pilot has reason to suspect attitude, airspeed or altitude sources are unreliable, and that aircraft not equipped with operating backup attitude, altimeter and airspeed instruments readily visible to the pilot are prohibited from operation. The practical risk is that an operator who removes limitations prematurely or fails to ensure proper backup instruments may be operating in breach of the Appendix’s operational instructions.