AD/PA-32/83 Amdt 1 - Control Wheel Attachment

Applicability and grouping: The Directive divides affected aircraft into Group A and Group B within the applicability table. Group A comprises defined serial number ranges of PA‑32R‑301 Saratoga II HP and PA‑32R‑301T Saratoga II TC; Group B comprises additional Saratoga serial ranges and PA‑32‑301FT and PA‑32‑301XTC Piper 6X and 6XT serial ranges. The Requirement text distinguishes a narrower immediate inspection obligation that applies only to Group A aircraft (with an exception for aircraft “already modified in accordance with the New Piper Aircraft Service Bulletin (SB) No. 1139, dated 28 August 2003”) and a retrofit obligation that applies to both Group A and Group B aircraft.

Two-part remedial structure: The instrument sets out two complementary remedial measures. Part I (Requirement 1) is an inspection and immediate corrective action focusing on the control wheel attachment screw and nut plate locking characteristics, and on reassembly using a thread‑locking compound. Part II (Requirement 2) prescribes fitment of a specified retainer clip (PN 104687‑002). The Directive requires Part I only for Group A (except those already modified under earlier SB 1139), but requires Part II for both Group A and Group B.

Objective standard and pass/fail tests: The tests set an objective minimum: “proper thread engagement (minimum one thread showing past the end of the nut plate).” The Directive commands replacement “before further flight” if insufficient engagement is found. It also prescribes a practical manual test for the nut plate: “If the screw can be fully inserted into the nut plate by hand (one thread showing past end of nut), then replacement of the nut plate is required before further flight.” These tests create binary outcomes that trigger immediate grounding until replacement is completed.

Mandatory method reference: Compliance is not freeform. The Directive mandates performance “in accordance with Part I” or “Part II” of SB No. 1139A dated 9 April 2004. It also prescribes a specific type of adhesive action: installation of the attachment screw “using Loctite thread‑locking compound.” The retainer clip is specified by part number, 104687‑002, implying a single approved component to meet the retrofit requirement.

Temporal framing and amendment mechanics: Compliance times are measured from 11 August 2004, with 25‑hour and 100‑hour thresholds. The Amendment states these times “remain unchanged by this issue,” and notes the Amendment becomes effective 17 March 2005. The Amendment corrects the earlier text to refer to SB No. 1139A dated 9 April 2004 rather than SB No. 1139 dated 9 April 2004, reflecting reliance on a corrected FAA AD.

Underlying safety rationale: The Background states the FAA received a report of a crash of a Model PA‑28‑181 after a control wheel attachment screw had unscrewed from its nut plate, leaving the control wheel free to spin. The investigation attributed the failure to a screw that was too short and a nut plate that lacked proper locking characteristics. The Directive’s measures mirror the identified failure modes: check screw length/thread engagement, check nut plate locking, apply thread locker, and add a retainer clip.

Mandate provenance: The Directive is issued by the Civil Aviation Safety Authority (CASA) via a signed delegate. It explicitly refers to FAA action (corrected FAA AD 2004‑14‑12 Amdt 39‑13721) and to New Piper Service Bulletins, indicating cross‑reference with both the manufacturer’s approved repair instructions and the foreign regulator’s corrective action.

Aircraft owners and operators: The primary parties who must act are owners/operators of the listed Piper PA‑32 models within the specified serial number ranges. The Directive’s applicability table lists serial ranges for Group A and Group B aircraft. Those owners/operators must ensure the inspections, replacements and installations are carried out within the prescribed compliance windows or before further flight in the event of a failed inspection test.

Maintenance organisations and certifying staff: Licensed maintenance facilities, maintenance engineers, and persons authorised to sign an aircraft maintenance release will perform the inspections and any corrective work “in accordance with” the specified service bulletin parts. The Directive prescribes specific actions (thread engagement measurement, nut plate locking assessment, installation of a retainer clip, and use of Loctite), so maintenance personnel must have the SB No. 1139A documentation and the specified parts and materials to perform compliant work.

Pilots and flight departments: Where an inspection reveals insufficient engagement or deficient nut plate locking characteristics, the aircraft must not be flown (“replace the screw before further flight”; “replacement of the nut plate is required before further flight”). Pilots and flight department managers must ensure that an aircraft with a failed inspection is grounded until corrective work is complete. The Directive therefore affects operational scheduling and availability.

Parts suppliers and logistics: The retrofit requires retainer clip part number 104687‑002 and a Loctite thread‑locking compound. Suppliers of Piper parts and maintenance supply chains must provide that specific part number and a suitable thread‑locking compound. The Directive implicitly affects inventory and procurement decisions for parts and adhesives.

Regulatory bodies and delegated signatories: CASA, through its delegate who issued the Directive, is the regulatory issuer. The Directive references an FAA AD and a New Piper Service Bulletin; these cross‑references mean the FAA and the manufacturer’s service information are relevant to interpretation and execution. While enforcement mechanisms are not stated in the source, the issuer is CASA and its delegates (signed by David Punshon).

Insurance and risk managers: Operators’ insurers and risk managers will be affected by the grounding and repair obligations. An operator who fails to comply with the Directive (or ignores “replace before further flight” instructions) may face increased underwriting risk, though the Directive text does not itself specify insurance consequences. The source does not address insurance, but the Directive’s immediate‑before‑flight replacement requirement imposes risk‑management obligations on operators.

Third parties and downstream purchasers: Prospective purchasers of affected serial‑number aircraft will have to verify whether the AD actions were completed. The Directive’s “already modified” exception for aircraft modified in accordance with earlier SB No. 1139 (dated 28 August 2003) creates a record‑checking task for buyers. The source does not specify documentation standards, but the practical effect is that purchasers must confirm compliance status to determine airworthiness.

Express duties in the Directive

• Inspection duty (Requirement 1.a and 1.b): For Group A aircraft (except those already modified under SB No. 1139 dated 28 August 2003), operators must “inspect the control wheel attachment screw for proper thread engagement (minimum one thread showing past the end of the nut plate), and replace the screw before further flight if insufficient thread engagement is found.” They must also “inspect the nut plate for sufficient locking characteristics,” and if the nut plate fails the manual insertion test, the nut plate must be replaced before further flight.

• Reassembly duty (Requirement 1.c): After inspection and any required replacements, the control wheel must be reassembled onto the control wheel shaft and the attachment screw installed “using Loctite thread‑locking compound.”

• Retrofit duty (Requirement 2): For both Group A and Group B aircraft in the applicability table, operators must “install retainer clip part number 104687‑002 in accordance with Part II of SB No. 1139A, dated 9 April 2004.”

• Conformance method duty: All actions are framed as to be performed “in accordance with” the specified Parts I and II of SB No. 1139A dated 9 April 2004. This delegates the procedural details and the methods to the manufacturer’s service bulletin as incorporated by reference.

Immediacy and temporal duties

• Before‑flight restrictions: Where inspections fail the specified tests, the Directive mandates replacement “before further flight.” That creates an immediate operational duty to ground the aircraft until the defect is remedied.

• Compliance windows: The Directive imposes time‑in‑service windows measured from 11 August 2004: Requirement 1 within 25 hours TIS; Requirement 2 within 100 hours TIS. The Directive states these compliance times remain unchanged by the Amendment.

Rights and limits within the source

• Exception for prior modification: The Directive grants an explicit exception from Requirement 1 for aircraft “already modified in accordance with the New Piper Aircraft Service Bulletin (SB) No. 1139, dated 28 August 2003.” The source text does not elaborate how to demonstrate the exception, but it recognises pre‑existing compliance under that older SB.

• Method specification as prescriptive, not permissive: The requirement to perform work “in accordance with” SB No. 1139A sets the method; there is no express option in the Directive to use an alternative technique, part, or compound. The Directive also specifies a single retainer clip part number. Within the source, no variance mechanism (such as an alternative means of compliance or AMOC provision) is stated.

• No penalties or enforcement mechanisms in the text: The Directive itself does not set out civil or criminal penalties, nor does it state enforcement procedures. It does, however, create obligations to be complied with; the source does not describe sanctions for non‑compliance.

Delegation and issuance

• Issuing authority: The Directive is issued by a CASA delegate (David Punshon). That indicates the administrative origin of the duty. The source does not define appeal or review rights against the Directive or set out a process for seeking exemptions.

Documentation and traceability requirements

• The Directive requires that work be accomplished “in accordance with” the service bulletin parts, which implies using the manufacturer’s instructions and likely recording maintenance releases, but the Directive text itself does not prescribe specific record‑keeping steps or certificates. Nevertheless, the “before further flight” phrase and the incorporation of a named service bulletin imply that standard maintenance documentation and release procedures should accompany the work.

What the Directive says

• The text of the Directive does not set out specific penalties, fines, or enforcement mechanisms. It prescribes mandatory actions and timeframes, and it includes explicit “before further flight” requirements when defects are found, but it does not, within the supplied text, specify civil penalties, regulatory sanctions, or enforcement processes for non‑compliance.

Operational enforcement consequences implied by the text

• Grounding effect: The Directive’s “replace … before further flight” provisions create an operational consequence that is immediate and binary: an aircraft that fails the inspection must be taken out of service until the mandated repair is carried out. In practice, that functions as an immediate grounding requirement for the affected aircraft; the Directive text itself requires replacement before further flight, which operationally prevents lawful flight until compliance.

• Compliance windows and retrospective deadlines: Compliance times are measured from 11 August 2004, with Requirement 1 within 25 hours TIS and Requirement 2 within 100 hours TIS. The Amendment states those times remain unchanged. Because the Amendment became effective on 17 March 2005, the compliance deadlines may already have elapsed for many aircraft when the Amendment became effective. The source does not spell out whether CASA would treat non‑compliance after the specified TIS windows differently from contemporaneous non‑compliance, nor does it spell out grace periods or retrospective enforcement approaches.

Regulatory enforcement mechanisms not present in the text

• No enforcement protocol: The Directive does not specify inspection, audit, or enforcement procedures, nor does it identify which CASA unit will monitor compliance, how CASA might verify compliance, or what sanctions would apply for failure to comply. The source contains no reference to infringement notices, civil penalties, or certificate suspensions.

• No appeal or AMOC provisions in the text: The source does not provide an avenue within the Directive language for seeking an alternative means of compliance (AMOC) or for appealing the requirement. The Directive is prescriptive, and the only flexibility it expressly provides is the exception for aircraft “already modified in accordance with” a specified prior SB.

Practical enforcement implications for operators

• Risk of regulatory action: Even absent explicit penalty language in the Directive, operators who fail to comply with an AD typically expose themselves to regulatory action by CASA under the broader aviation safety regulatory regime. The Directive itself does not state that, so any assertion beyond the Directive text would be an inference. The source does, however, identify the delegate and the regulatory provenance, making it clear CASA issued the requirement.

• Insurance and commercial consequences: The Directive does not address insurers, but the “before further flight” requirement implies that continued operation without remedy would be inconsistent with the Directive. The consequence in practice may be that aircraft flown in apparent contravention of an AD could encounter commercial and insurance consequences, even though the Directive text does not spell them out.

• Manufacturer and manufacturer SB reliance: Because the Directive requires actions “in accordance with” SB No. 1139A, enforcers and inspectors checking compliance will likely seek evidence that the service bulletin instructions were followed. The Directive therefore channels enforcement attention toward maintenance records demonstrating conformity with the SB.

References to other regulatory instruments in the source

• FAA AD cross‑reference: The Directive explicitly refers to a corrected FAA AD, “Corrected FAA AD 2004‑14‑12 Amdt 39‑13721.” The Background explains Amendment 1 is issued in response to the issue of a corrected copy of the related FAA AD, and that the only part requiring correction in this Directive was the reference to the correct service bulletin part number (SB No. 1139A). The Directive therefore interacts with and mirrors FAA action addressing the same technical failure mode.

• Manufacturer service bulletin incorporation: The Directive requires actions “in accordance with Part I” and “Part II” of New Piper Service Bulletin No. 1139A dated 9 April 2004, and it references an earlier SB No. 1139 dated 28 August 2003 for an exception. The AD thus incorporates the manufacturer’s maintenance instructions into a regulatory obligation. That creates an intersection between regulatory action and manufacturer technical material.

How this interaction operates in practice

• Deference to manufacturers’ methods: By mandating compliance “in accordance with” specific parts of the manufacturer’s service bulletin, the Directive effectively makes the SB the operative procedural standard for compliance. That delegates the precise technical steps and tolerances to the manufacturer’s publication, while CASA retains regulatory authority to require the SB work be done.

• Cross‑jurisdictional consistency: The reference to the FAA AD indicates alignment with a major foreign regulator’s corrective direction. This can facilitate operators who operate internationally or who are familiar with FAA material, but also means that changes or corrections in the FAA AD (as occurred here) can necessitate consequential corrections to the CASA text, as this Amendment demonstrates.

Limits and omissions in interaction with other law

• No direct citation to Australian Civil Aviation Regulations in the text: The Directive does not explicitly quote or cite specific provisions of the Civil Aviation Regulations or other Australian statutory instruments that empower CASA to issue the AD. The source therefore leaves implicit the statutory power health, focusing instead on the operational directive and its technical requirements.

• No discussion of certificate validity or airworthiness approvals: The Directive does not explicitly state how compliance interacts with airworthiness certificates, maintenance release processes, or continuing airworthiness obligations beyond the immediate requirements. The practical effect is that compliance is required by the Directive, but the source does not articulate downstream legal consequences (re: certificate suspension, etc.) or procedural steps (re: notification to CASA).

Potential for audit and record assessment

• Evidence of compliance likely to rely on SB adherence: Because the Directive requires SB‑based work, inspectors or auditors will likely assess maintenance records against the SB steps. The Directive does not itself specify records to be retained or lodged with CASA, but the operational interplay with existing regulatory frameworks for continuing airworthiness records is implied: maintenance release paperwork demonstrating SB instructions were followed will be the natural evidence of compliance.

Textual summary of the Amendment

• Identity and effective date: The instrument is AD/PA‑32/83 Amdt 1, effective 17 March 2005, issued 4 February 2005 by a delegate of the Civil Aviation Safety Authority (signed David Punshon).

• Purpose of Amendment 1: The Amendment was issued “in response to the issue of a corrected copy of the related FAA AD,” specifically to correct a reference in Requirement 1 that previously read “Part I of SB No. 1139 dated 9 April 2004” to the correct “Part I of SB No. 1139A dated 9 April 2004.” The Background states “The only part requiring correction of this Directive was Requirement 1. text, ‘Part I of SB No. 1139 dated 9 April 2004’ which was changed to ‘Part I of SB No. 1139A dated 9 April 2004’.”

• Retained compliance times: The Amendment confirms that the compliance times established in the Directive remain unchanged by the Amendment, explicitly stating “The compliance times remain unchanged by this issue.”

Pre‑Amendment references in the source

• Prior SB reference: The Requirement text also contains an exception for aircraft “already modified in accordance with the New Piper Aircraft Service Bulletin (SB) No. 1139, dated 28 August 2003.” That indicates the Directive recognises an earlier SB modification and treats it as an exception to the inspection obligation described in Requirement 1.

Interaction between AD, Amendment and FAA correction

• Triggering cause: The Amendment was triggered by the issuance of a corrected FAA AD (FAA AD 2004‑14‑12 Amdt 39‑13721) which itself corrected parts of the text relating to the service bulletin reference. The source explicitly links the Amendment to that corrective action, indicating a dependence on the FAA communication for precise SB identification.

• Nature of the correction: The textual correction in the Amendment is specific and narrow: the corrected reference to SB No. 1139A dated 9 April 2004 replaces an incorrectly cited SB reference. No other substantive change to requirements or compliance windows is recorded in the Amendment text supplied.

Temporal context and retrospective compliance

• Compliance windows anchored to 11 August 2004: The Directive sets compliance windows measured from 11 August 2004 (25 hours TIS for Requirement 1; 100 hours TIS for Requirement 2). The Amendment became effective 17 March 2005 but states compliance times remain unchanged. The Directive does not explain how CASA will treat aircraft that exceeded those TIS thresholds in the interval between 11 August 2004 and the effective date of the Amendment. The Amendment therefore corrects a textual reference without altering the compliance deadlines.

Document lineage evident in the source

• AD title repetition: The source reproduces the AD title and amendment lines multiple times (e.g. “AD/PA‑32/83 Amdt 1” and “Control Wheel Attachment 3/2005”), indicating the AD and its Amendment are the operative documents. The Background narrative supplies the proximate technical cause and the linkage to FAA action.

What the source contains

• No litigation reported: The Directive text and its Background supplied here do not mention any litigation, court proceedings, disputes, or legal challenges arising from the Directive, the Amendment, the FAA AD, or the service bulletin. There are no cases named in the source, and no references to administrative appeals or reviews.

Implications of the absence of litigation in the source

• Absence of precedent in the instrument: Because the source supplies no litigation history, it provides no judicial interpretation, no set of legal arguments that were tested against the Directive’s obligations, and no case law setting limits on CASA’s power in the context of this AD.

• Administrative correction rather than dispute: The Amendment’s stated purpose was to correct a cross‑reference to a service bulletin following the issuance of a corrected FAA AD. That administrative correctionary posture typically does not suggest litigation. The source frames the Amendment as technical correction rather than remedial response to a contested enforcement action.

How to proceed if litigation occurred but is not recorded here

• External searches required: If an operator, maintainer or purchaser requires information on any legal challenges to this Directive or the corrected FAA AD, that information is not contained in the supplied text. A separate search of case law and administrative records would be necessary. The source does not supply any hints of litigation or appeals to administrative tribunals.

Interpretation traps in the Directive language

• Differing SB references and exception wording: The Directive grants an exception for aircraft “already modified in accordance with the New Piper Aircraft Service Bulletin (SB) No. 1139, dated 28 August 2003,” yet the corrected Requirement 1 explicitly requires compliance “in accordance with Part I of SB No. 1139A dated 9 April 2004.” Operators and maintainers must be precise when determining whether their aircraft fall under the exception. The Amendment corrects a prior textual error and replaces an earlier SB reference with SB No. 1139A, which can cause confusion when comparing records that mention SB No. 1139 (28 August 2003), SB No. 1139 (9 April 2004), and SB No. 1139A (9 April 2004). The source indicates this correction was necessary because of a corrected FAA AD.

• Practical measurement uncertainty: The Directive uses two related but subtly different expressions to describe acceptable thread engagement: first, “proper thread engagement (minimum one thread showing past the end of the nut plate),” and second, “If the screw can be fully inserted into the nut plate by hand (one thread showing past end of nut), then replacement of the nut plate is required.” The first reads as a minimum engagement threshold; the second reads as a hand‑insertion test for nut plate locking. In practice, applying these standards requires an inspector to judge what “one thread showing past the end of the nut plate” looks like on the particular screw/nut geometry and whether the screw can be “fully inserted … by hand.” Inspectors must accordingly interpret threshold measures consistently, but the Directive does not provide measurement tolerances or a torque/engagement gauge procedure.

• “Before further flight” grounding effect: The requirement that replacement is “required before further flight” when criteria are not met imposes an immediate grounding obligation. Operators must be prepared for immediate aircraft downtime if inspections reveal failures. The Directive does not specify a maximum permitted delay for replacement once the defect is found; the plain text requires replacement prior to any next flight.

• Part number specificity and supply chain risk: Requirement 2 mandates installation of “retainer clip part number 104687‑002.” There is no alternative part number provided in the source. If that part is scarce or backordered, operators have a compliance problem: the Directive imposes a retrofit within the compliance window, but the source does not provide a substitution or an alternative means of compliance.

Temporal oddity and compliance windows

• Compliance windows measured from an earlier date: Compliance times are given “after 11 August 2004,” but the Amendment became effective on 17 March 2005. Operators must interpret whether an aircraft that has exceeded the TIS thresholds but has not yet completed the work is in breach. The Directive states the times remain unchanged, but does not provide a transitional compliance mechanism; that may create practical confusion.

Dependence on an external service bulletin for details

• Incorporation of SB No. 1139A: The Directive repeatedly requires performance “in accordance with” the specified service bulletin parts. The AD itself does not reproduce the SB’s procedural details, tolerances, or drawings; those are contained in the SB. Operators therefore must obtain SB No. 1139A dated 9 April 2004 to know the detailed steps. In some circumstances, there may be costs or delays in obtaining that SB.

Specified adhesive product type without guidance on application

• Loctite usage required: Requirement 1.c requires installation of the attachment screw “using Loctite thread‑locking compound.” The Directive does not identify a specific Loctite grade, nor does it state application quantities, curing times, or compatibility with plating, paint and tolerances. Maintenance personnel must consult the SB or other technical guidance for appropriate Loctite selection and application. The Directive’s generic reference to Loctite leaves room for interpretation and potential inconsistency unless the SB provides the detail.

Record evidence and the prior‑modification exception

• Demonstrating prior compliance: The Directive exempts aircraft “already modified in accordance with the New Piper Aircraft Service Bulletin (SB) No. 1139, dated 28 August 2003” from Requirement 1. The instrument does not stipulate what documentary evidence suffices to show the prior modification. In practice, operators should expect to demonstrate that the SB work was performed and released in conformance with the SB. The source does not specify the form of that evidence.

Ambiguity over who verifies compliance with the SB

• Who confirms SB conformance: The Directive commands actions “in accordance with” the SB, but the text does not set out who has authority to certify SB compliance. The implicit practical consequence is that licenced maintenance certifying staff will sign maintenance releases, but the Directive does not prescribe a certifier or method. That leaves room for practical variation in local practice.

Stepwise compliance checklist anchored to the Directive text

1. Identify affected aircraft: Consult the applicability table in the Directive and confirm whether your aircraft serial number falls within the Group A or Group B serial ranges listed. The Directive identifies serial ranges for PA‑32R‑301 Saratoga II HP, PA‑32R‑301T Saratoga II TC, PA‑32‑301FT Piper 6X and PA‑32‑301XTC Piper 6XT (Applicability table).

2. Determine whether Requirement 1 applies: For aircraft in Group A, determine whether the aircraft was “already modified in accordance with the New Piper Aircraft Service Bulletin (SB) No. 1139, dated 28 August 2003.” If so, Requirement 1 is excepted for that aircraft. If not, Requirement 1 (inspection and corrective action per Part I of SB No. 1139A) applies.

3. Obtain the required service bulletin: Acquire New Piper Service Bulletin No. 1139A dated 9 April 2004. The Directive requires actions “in accordance with Part I” and “Part II” of that SB. The SB will contain procedural steps, torque values, parts diagrams and any additional notes that the Directive does not reproduce.

4. Schedule maintenance within the compliance window: The Directive requires Requirement 1 within 25 hours time in service and Requirement 2 within 100 hours time in service, both measured after 11 August 2004. Schedule inspections and retrofits to meet the appropriate TIS windows. Bear in mind the Amendment states these compliance times remain unchanged; execute work promptly if any windows remain open for your aircraft.

5. Perform Part I inspection and corrective action (Group A only, unless exempt): Following Part I of SB No. 1139A:

   • Inspect the control wheel attachment screw for thread engagement. The Directive sets the objective: “minimum one thread showing past the end of the nut plate.”
   • If insufficient thread engagement is found, replace the screw before further flight.
   • Inspect the nut plate for locking characteristics. The Directive prescribes a hand test: “If the screw can be fully inserted into the nut plate by hand (one thread showing past end of nut), then replacement of the nut plate is required before further flight.”
   • Reassemble the control wheel onto the control wheel shaft and install the attachment screw using a Loctite thread‑locking compound (Requirement 1.c).

6. Perform Part II retrofit (Group A and Group B): Install retainer clip part number 104687‑002 in accordance with Part II of SB No. 1139A. Obtain PN 104687‑002 from an authorised parts supplier and follow the SB for location and installation method.

7. Grounding if defects are found: The Directive imposes a clear grounding rule: replace the screw or nut plate “before further flight” if inspections fail the specified tests. Ensure aircraft are not dispatched until the required remedial work is complete.

8. Use appropriate parts and materials: The Directive is specific about the retainer clip PN and the use of Loctite thread‑locking compound for reassembly. Confirm the Loctite grade and any curing instructions from SB No. 1139A or manufacturer guidance before application.

9. Document the work: While the Directive does not prescribe a specific paperwork form, standard maintenance practice requires recording the inspection results, parts replaced (including PN 104687‑002), the service bulletin reference used (SB No. 1139A, Part I/Part II), and the certifying engineer’s sign‑off in the aircraft maintenance records. Because the AD grants an exception for aircraft already modified under SB No. 1139 (28 August 2003), retention of documentation demonstrating that prior SB work is important.

10. Retain the service bulletin and evidence for audits: Keep a copy of SB No. 1139A and all maintenance records showing compliance, including photos where appropriate. If compliance was completed within the specified TIS windows, preserve the evidence to demonstrate the aircraft’s continuing airworthiness.

Operational and logistical tips grounded in the Directive

• Procurement planning: Where the retainer clip PN 104687‑002 is not in stock, initiate procurement immediately. The Directive provides no alternate PN or AMOC in its text.

• Loctite selection: The Directive requires “Loctite thread‑locking compound” but does not identify the grade. Consult SB No. 1139A or manufacturer guidance for the correct Loctite grade and cure requirements; do not assume any Loctite product is acceptable without verification.

• Clarify the prior modification exception: If an aircraft’s records allege modification under SB No. 1139 dated 28 August 2003, verify the paperwork to ensure it conforms to that SB and is acceptable evidence that Requirement 1 is inapplicable.

• Immediate remedial planning: Because failures detected by the tests require replacement before further flight, plan maintenance slots and ensure availability of qualified certifying staff so aircraft are not left unusable for long periods.

• Cross‑reference FAA material where useful: The Directive references corrected FAA AD 2004‑14‑12 Amdt 39‑13721. While the Directive’s operative instructions are CASA’s, the FAA AD and the SB may contain clarifications; use them to inform the technical work but rely on SB No. 1139A as mandated by the Directive.

Concluding compliance checklist summary

• Confirm applicability (serial number and Group).
• Obtain SB No. 1139A dated 9 April 2004.
• For Group A aircraft not exempted by prior SB 1139 (28 Aug 2003), perform Part I inspection and required replacements, using Loctite on reassembly.
• For all Group A and Group B aircraft in the applicability, install retainer clip PN 104687‑002 per Part II.
• Adhere to compliance windows measured from 11 August 2004 (25 hours TIS for Requirement 1; 100 hours TIS for Requirement 2), and document the work and sign‑off before returning the aircraft to service.