AD/ML-M6/3 - Elevator Controls

The AD centres on two main concepts: physical visual identification of critical control connections, and a mandated procedural verification step in maintenance programmes. The visual identification concept is operationalised by colour-coding four discrete points of the elevator control linkage with yellow enamel paint, as specified in Requirement 1. The AD points to Maule Mandatory Service Bulletin No. 30 (dated 4 March 2008) as the prescriptive implementation document for the marking work; thus the Service Bulletin is the technical reference for how the marking is to be accomplished.

The procedural concept is operationalised by mandating insertion of a specific caution into the rigging procedure section of the operator’s FAA-approved maintenance programme (Requirement 2). The wording required is explicit and prescriptive: it instructs personnel to perform a physical check of elevator operation after elevator cable reconnection or cable installation by pulling back on the control to verify the elevators are in the UP position. The AD further provides two compliance pathways for the maintenance-programme insertion: either insert a copy of the AD into the FAA-approved maintenance programme, or insert the particular text that appears at the bottom of page 3 of Maule Mandatory Service Bulletin No. 30.

The AD’s applicability concept is narrow and discrete. It lists particular models (M-6-180 and M-6-235) and specified serial numbers in Table 1, which means the mandate attaches only to aircraft whose serials are enumerated. The compliance timing concept sets a short, specific deadline tied to an event or a fixed period: compliance must be achieved before the next disconnection of an elevator control cable or, alternatively, within 12 calendar months after the effective date (12 February 2009), whichever is earlier.

The safety rationale concept is explicit in the AD’s Background. CASA reports two accident investigations where reversed elevator control rigging was implicated. The AD links the visual and procedural interventions directly to the risk of a mechanic rigging the controls in reverse, producing elevator movement opposite to control input and the possibility of loss of control.

Finally, the AD references external instruments as part of the compliance architecture. It references Maule Mandatory Service Bulletin No. 30 as the technical implementation standard and refers operators to FAA AD 2008-24-02 Amdt 39-15742 dated 10 November 2008. It also reminds operators that Civil Aviation Regulation (1988) 42G imposes additional requirements when parts of the flight control system are assembled, adjusted, repaired, modified or replaced during maintenance (Note 1). These cross-references indicate the AD’s placement in a broader regulatory and technical ecosystem.

The AD directly affects owners, operators and maintenance organisations responsible for the specific Maule M-6 aeroplanes and serial numbers listed in Table 1 of the AD. Table 1 names particular serial numbers for the M-6-180 and M-6-235 models. Only those aircraft whose model and serial numbers appear in Table 1 fall within the AD’s applicability as presented in the document; the AD does not state that it applies beyond the enumerated serial numbers.

Mechanics and maintenance personnel are the actors whose behaviour is directly regulated. Requirement 1 instructs them to apply yellow enamel paint to specified points on the elevator control system, and Requirement 2 requires maintenance-programme administrators to insert a precise caution into the rigging procedure section of the FAA-approved maintenance programme. The CAUTION text is targeted at maintenance personnel performing cable reconnections or cable installations, instructing them to carry out a verification step before flight.

Regulatory decision-makers at CASA are the issuing authority. The AD is signed by James Coyne, Delegate of the Civil Aviation Safety Authority (22 December 2008), and the AD has an effective date of 12 February 2009. The AD therefore operates as a CASA regulatory instrument addressed to Australian-registered operators and maintenance organisations responsible for the covered aircraft.

Other actors with an interest include the manufacturer or service bulletin issuer, Maule Aerospace Technology, Inc., because the AD directs following its Mandatory Service Bulletin No. 30 dated 4 March 2008. The AD also interacts with FAA-approved maintenance programmes, because it contemplates inserting the caution into those programmes. Note 2 in the AD mentions FAA AD 2008-24-02, indicating that FAA regulatory action on the same safety issue exists in the United States and may be relevant to operators who hold FAA-approved programmes or follow FAA guidance.

Finally, CASA reminds operators of a regulatory cross-obligation in Civil Aviation Regulation (1988) 42G where any part of the flight control system is assembled, adjusted, repaired, modified or replaced in the course of maintenance. That reminder signals that where the required work involves assembly, adjustment, repair, modification or replacement of flight control components, additional regulatory requirements under that regulation will need to be observed; the AD does not reproduce those additional requirements but explicitly brings them to operators’ attention (Note 1).

The AD imposes two discrete duties on affected parties.

Duty 1 (marking): Operators or maintenance personnel must colour-code four specified components using yellow enamel paint, following Maule Mandatory Service Bulletin No. 30 dated 4 March 2008. The specified components to mark are: the top of the rear elevator control horn; the elevator control cable end attached to that top of the rear control horn; the bottom of the forward elevator control horn; and the elevator control cable end attached to that bottom of the forward control horn (Requirement 1). The AD directs following the Service Bulletin as the means to perform this duty.

Duty 2 (maintenance-programme amendment): Operators must insert a specified caution into the rigging procedure section of the FAA-approved maintenance programme or maintenance manual. The AD prescribes the exact wording of the caution: “CAUTION - BEFORE FLIGHT WHENEVER ELEVATOR CABLES ARE RECONNECTED OR NEW CABLES INSTALLED: Always check operation of elevators after a cable reconnect by pulling back on the control and ascertain that the elevators are in the UP position.” The AD notes that compliance may be achieved by inserting a copy of the AD or by inserting the text located on the bottom of page 3 of Maule Mandatory Service Bulletin No. 30 into the FAA-approved maintenance programme (Requirement 2 and the implementation note).

Timing duty: The AD prescribes when the duties must be completed. Compliance must be accomplished before the next disconnection of the elevator control cable for any reason, or within 12 calendar months after the AD’s effective date, 12 February 2009, whichever occurs first (Compliance).

Rights and consequential allowances stated in the AD are narrow. The AD defines a method of compliance (follow the Maule Service Bulletin) and an alternative method for the maintenance-programme insertion (copy of the AD or specific text from the SB). The AD does not set out exemptions, waivers, or alternative approval processes within the text provided; it also does not state an appeals process or administrative review mechanism in this document. The AD does not itself articulate monetary compensation, funding, or technical assistance to cover the costs of compliance.

Regulatory overlay: The AD contains a reminder (Note 1) that Civil Aviation Regulation (1988) 42G imposes additional requirements where flight control system components are assembled, adjusted, repaired, modified or replaced during maintenance. That note imposes an obligation on operators to observe any statutory requirements under that regulation when the specified types of work occur as part of compliance with this AD.

The AD embeds a technical reference obligation: following Maule Mandatory Service Bulletin No. 30. This makes the Service Bulletin a functional part of the duty structure; operators must use it as the technical standard for the colour-coding work, unless an alternative compliant method is permitted under some other authority not stated in the AD.

The AD text supplied does not specify civil or criminal penalties for non-compliance within the document itself. The AD states the effective date (12 February 2009) and prescribes the compliance timeframe, but it does not enumerate enforcement actions, infringement notices, or fine amounts in the text provided. There is also no express text in the AD setting out remedial orders, grounding powers, or formal enforcement procedures within this document.

The AD does, however, include a regulatory cross-reference in Note 1 to Civil Aviation Regulation (1988) 42G, advising operators that additional statutory requirements apply when flight control system parts are assembled, adjusted, repaired, modified or replaced during maintenance. That cross-reference signals that other statutory compliance obligations may attach to the physical works required to implement the AD. The AD’s mention of this regulation indicates a potential enforcement pathway outside the AD itself, but the AD does not state the content or penalties associated with that regulation.

In practice, Airworthiness Directives issued by CASA are regulatory instruments intended to be complied with; this AD sets mandatory duties (marking and maintenance-programme insertion) and a deadline. The AD’s statement of compliance timing creates an observable legal obligation whose breach would be determinable by inspection or audit of the aircraft and the operator’s maintenance programme. The AD does not, in its text, identify the body or mechanism that will verify compliance, nor the remedial or punitive measures that will apply to non-compliance.

Because the AD references an FAA AD (2008-24-02) and a manufacturer Service Bulletin as the technical standard, failure to follow those documents as required by the AD could be used in an enforcement context as evidence of non-compliance with the CASA AD. The AD’s Reminder (Note 1) further indicates that when the work includes assembly/adjustment/repair/modification/replacement of flight control parts, additional statutory obligations under Civil Aviation Regulation (1988) 42G will arise and those statutory obligations carry their own compliance and enforcement mechanisms, though those mechanisms and sanctions are not described here.

Readers should note that the AD as provided is an operational regulatory instrument that sets duties and deadlines; this document does not list penalties or a formal enforcement schedule. Any enforcement action, penalties or sanctions that might follow non-compliance would come from the broader regulatory framework under which CASA operates, and those details are not contained in the text of this AD.

The AD explicitly interacts with two external instruments and a manufacturer Service Bulletin. First, it requires compliance with Maule Aerospace Technology, Inc. Mandatory Service Bulletin No. 30 dated 4 March 2008 for the detailed implementation of the colour-coding requirement (Requirement 1). The Service Bulletin functions as the technical standard the AD directs operators to follow. The AD further allows compliance with the maintenance-programme insertion by placing a copy of the AD or the text located on the bottom of page 3 of the Service Bulletin into the FAA-approved maintenance programme; that creates a direct operational linkage between the AD and the manufacturer’s Service Bulletin.

Second, Note 2 in the AD refers to FAA AD 2008-24-02 Amdt 39-15742 dated 10 November 2008. The AD does not reproduce the FAA AD’s contents but signals a substantive correspondence or alignment with an FAA regulatory action on the same safety issue. For operators who also operate under FAA oversight, or who hold FAA-approved maintenance programmes, this creates a cross-jurisdictional reference point. The AD’s language suggests that the FAA’s action is relevant and that operators should be aware of the FAA AD.

Third, Note 1 draws attention to the Civil Aviation Regulation (1988) 42G, which the AD reminds operators requires additional requirements to be complied with if any part of the flight control system of an Australian aircraft is assembled, adjusted, repaired, modified or replaced in the course of maintenance. This places the AD within the broader statutory regime that governs maintenance activity on Australian aircraft. The AD does not restate the contents of Regulation 42G, but it explicitly flags that implementing the AD may trigger further statutory obligations under that regulation.

Operationally, the AD therefore sits at the intersection of manufacturer guidance (Service Bulletin), CASA regulatory direction (this AD), FAA regulatory action on the same subject (FAA AD 2008-24-02), and underlying civil aviation regulations (Civil Aviation Regulation (1988) 42G). This means that work done to comply with the AD is not necessarily limited to the paint and manual insertion tasks in isolation: where the physical work involves assembling, adjusting, repairing, modifying or replacing flight control components, operators must also ensure compliance with any additional regulatory provisions in Regulation 42G. The AD does not set out conflict-resolution rules where obligations from the Service Bulletin, FAA AD, and Civil Aviation Regulations differ; it simply references these instruments, making them part of the compliance environment that operators must navigate.

Practically, the AD’s allowance to insert either a copy of the AD or the specific text from the Service Bulletin into the FAA-approved maintenance programme creates a point of interaction between CASA direction and FAA-approved documentation. Operators who operate under FAA-approved programmes will need to adopt one of the AD’s two specified routes to amend their rigging procedures. The AD does not describe any approval process for alternative means of compliance within the text provided.

The AD text as supplied contains its identification and effective date but does not record subsequent amendments within the document. It is titled AD/ML-M6/3 Elevator Controls 2/2009, and it specifies that the Airworthiness Directive becomes effective on 12 February 2009. The document is dated 22 December 2008 and signed by James Coyne, Delegate of the Civil Aviation Safety Authority. The AD also references FAA AD 2008-24-02 Amdt 39-15742 dated 10 November 2008 and Maule Mandatory Service Bulletin No. 30 dated 4 March 2008, but it does not indicate any later revision history in the supplied text.

No amendment or revocation provisions, supersession clauses, or later-version notes are contained in the provided text. There is no text describing how amendments to Maule Service Bulletin No. 30, or subsequent FAA AD updates, would affect the obligations in this AD. The document does not include a revision table or an amendment log that would show changes to the AD after issuance. If amendments have been made post-issuance, they are not included in the text provided for analysis.

The AD does contain a practical implementation instruction that the maintenance-programme insertion may be achieved by inserting a copy of the AD or inserting the specified text from the Service Bulletin, which constitutes a form of internal cross-reference but is not an amendment. The AD does not articulate any formal process for requesting deviations, exemptions or alternative means of compliance within the text supplied.

Because the supplied AD does not include an amendment history, readers seeking whether the AD has been amended, superseded, or revoked will need to consult CASA’s official AD registry or subsequent regulatory instruments; such consultation is outside the scope of the text provided here and is not set out in this document.

The AD text supplied does not reference any litigation, judicial decisions, appeals, or administrative review outcomes. There are no cases named, no reference to court proceedings, and no mention of any disputes arising from implementation of this AD in the provided document.

The AD’s Background section refers to two accident reports in which reversed elevator control rigging was a factor, and those accident reports are cited as the impetus for the AD. However, the AD does not reproduce or summarise any legal proceedings relating to those accidents, nor does it identify any enforcement actions that were litigated. The document is silent on any legal challenges to the AD itself, and it does not record any precedent, adjudication, or settlement related to this AD.

If litigation or administrative appeal history exists, it is not documented in the supplied AD. Users who require any such litigation history must seek external records from CASA, judicial registries or other public sources; those records are not included in the provided text.

The AD contains a number of precise specifications and timing conditions that can create compliance pitfalls if not carefully followed.

1. Applicability is serial-specific. The AD applies only to the M-6-180 and M-6-235 models and only to the serial numbers detailed in Table 1. Operators must check the aircraft’s serial number against the exact serial lists in Table 1; a mistaken assumption that the AD applies to all M-6s would be incorrect. The AD’s table lists ranges and discrete serial numbers, and compliance obligations attach only to the vehicles enumerated.

2. The marking instructions are precise in both colour and location. Requirement 1 mandates use of yellow enamel paint and identifies four exact points to be colour-coded: top of the rear elevator control horn; elevator control cable end attached to that top; bottom of the forward elevator control horn; elevator control cable end attached to that bottom. Using a different colour, a different paint type, or marking different points would not be strictly following the AD text as supplied. The AD references Maule Mandatory Service Bulletin No. 30 for how to follow the marking instruction; operators must ensure they follow the Service Bulletin as incorporated by the AD.

3. The procedural insertion requires exact wording and placement. Requirement 2 prescribes the precise CAUTION statement that must be inserted into the rigging procedure section of the FAA-approved maintenance programme. The AD states that the insertion may be achieved by inserting a copy of the AD or inserting the text on the bottom of page 3 of Maule Mandatory Service Bulletin No. 30. If an operator amends their programme with different wording or places the caution in a different section, that may not satisfy the AD as written.

4. Timing is event-tied and time-limited. Compliance must occur before the next time the elevator control cable is disconnected for any reason or within 12 calendar months after the effective date (12 February 2009), whichever is first. For aircraft whose elevator cable will not be disconnected for more than 12 months, the latter clause imposes a fixed deadline. Missing either the event-tied window or the 12-month deadline would be a compliance breach under the AD’s terms.

5. Additional regulatory obligations may be triggered. Note 1 reminds operators that Civil Aviation Regulation (1988) 42G requires additional requirements if the flight control system is assembled, adjusted, repaired, modified or replaced as part of the maintenance. If compliance with the AD’s marking requirement involves any of those activities, operators must observe the additional regulatory requirements under Regulation 42G; the AD does not describe those requirements but explicitly warns they exist. Treating the AD’s tasks as standalone without checking Regulation 42G would be a potential trap.

6. Technical standard dependency. The AD requires following Maule Mandatory Service Bulletin No. 30 dated 4 March 2008. If an operator does not have access to that Service Bulletin or uses an outdated or amended version without checking, they may fail to comply with the AD’s incorporation of that document.

7. Cross-jurisdiction interaction. The AD references FAA AD 2008-24-02. Operators who operate internationally or who follow FAA-approved programmes should ensure that their chosen method of compliance (copying the AD into the programme or inserting the SB text) aligns with any FAA requirements they are subject to. Failing to reconcile CASA’s AD with FAA programme requirements could create administrative or regulatory inconsistencies.

8. Lack of penalty text in the AD. The AD does not list penalties or an enforcement procedure. Operators should not confuse that omission with an absence of enforcement powers in the broader regulatory framework. The AD’s obligations remain mandatory; the absence of specified penalties in the AD itself may nevertheless expose operators to regulatory action under related statutes.

9. Maintenance-programme scope. The AD requires insertion into the rigging procedure section of the FAA-approved maintenance programme (for example, the maintenance manual). Operators whose maintenance documentation is structured differently should ensure the caution is placed in an equivalent, FAA-approved rigging-procedure location. Failure to place the CAUTION in the programme area that is actually used during rigging may reduce the effectiveness of the mandated check and could be a compliance oversight.

10. Execution detail and human factors. The AD’s core intent is to reduce reversed rigging errors via visual cues and a warning check. However, the AD does not provide a verification protocol for how to confirm that the yellow paint remains visible and legible over time, nor does it prescribe periodic inspection of the markings. Operators should note that the AD requires the initial application and the insertion of the CAUTION but does not set explicit ongoing inspection intervals for the markings in the text supplied.

Follow these steps strictly as set out in the AD text to achieve compliance:

1. Confirm applicability. Consult Table 1 in the AD and verify the aircraft’s model and serial number against the list for M-6-180 and M-6-235. Only aircraft with serial numbers listed in Table 1 are subject to the AD.

2. Obtain Maule Mandatory Service Bulletin No. 30 dated 4 March 2008. Requirement 1 instructs following this Service Bulletin to perform the colour-coding. The AD explicitly directs following the Service Bulletin as the implementation method for the paint work.

3. Prepare materials and personnel. Acquire yellow enamel paint as specified by the AD. Identify competent maintenance personnel to perform the paint application, ensuring they have access to the Service Bulletin instructions referenced by the AD.

4. Apply the colour-coding. Using yellow enamel paint, mark the following four points:

   • the top of the rear elevator control horn,
   • the elevator control cable end attached to the top of the rear control horn,
   • the bottom of the forward elevator control horn,
   • the elevator control cable end attached to the bottom of the forward control horn. Follow the detailed steps and any tolerances or preparatory instructions set out in Maule Mandatory Service Bulletin No. 30 as the AD requires.

5. Amend the maintenance programme. Insert the exact CAUTION wording into the rigging procedure section of the FAA-approved maintenance programme or maintenance manual. The required text is: “CAUTION - BEFORE FLIGHT WHENEVER ELEVATOR CABLES ARE RECONNECTED OR NEW CABLES INSTALLED: Always check operation of elevators after a cable reconnect by pulling back on the control and ascertain that the elevators are in the UP position.” The AD states this insertion may be achieved by inserting a copy of the AD or by inserting the text located on the bottom of page 3 of Maule Mandatory Service Bulletin No. 30 into the FAA-approved maintenance programme. Use one of those two methods to meet the AD’s requirement.

6. Observe the compliance deadline. Complete the marking and the maintenance-programme insertion either before the next time the elevator control cable is disconnected for any reason or within 12 calendar months after the AD’s effective date (12 February 2009), whichever occurs first. Plan the work so that the event-tied and time-limited clauses are respected.

7. Account for additional regulatory steps. If the paint application or any other work required to comply with the AD involves assembling, adjusting, repairing, modifying or replacing any part of the flight control system, ensure that the additional requirements under Civil Aviation Regulation (1988) 42G are observed. The AD explicitly reminds operators of those additional regulatory requirements.

8. Cross-reference FAA AD if applicable. Note that FAA AD 2008-24-02 is referred to in the AD (Note 2). If you hold an FAA-approved maintenance programme or are otherwise subject to FAA regulation, coordinate the maintenance-programme amendment so it satisfies both CASA’s AD and any applicable FAA requirements.

9. Practical record-keeping (operational suggestion). Although the AD text does not specify a record-keeping protocol, best practice in implementing ADs is to record the compliance work in the aircraft’s maintenance records, noting the AD number, the Service Bulletin reference, the date of the marking and maintenance-programme change, and the person who performed and signed off the work. The AD’s own text requires the insertion into the FAA-approved maintenance programme; documenting that insertion will create an auditable trace.

10. Maintain the markings. The AD does not prescribe inspection intervals for the yellow enamel paint after initial application. Consider incorporating a check of the markings into routine maintenance or pre-flight inspections to ensure the yellow identification remains visible and effective, particularly where the efficacy of the measure depends on maintenance personnel being able to identify the correct control ends visually during rigging operations.

By following the AD’s explicit technical direction (Service Bulletin No. 30) for the painting task and by inserting the exact CAUTION wording into the rigging procedure of the FAA-approved maintenance programme, an operator satisfies the two mandatory duties set out in this AD within the prescribed timeframe.