Airworthiness Directives 2004 - Revocation and Remaking - Airbus Industrie A319 A320 and A321 Series Aeroplanes

Airworthiness directive. An airworthiness directive is a mandatory regulatory instrument issued under the Civil Aviation Safety Regulations that requires an operator, owner, or maintenance provider to inspect, modify, repair, replace, or perform some other action on an aircraft or component within a specified time. It is the primary tool CASA uses to correct an unsafe condition that has been identified in a type design or in service. Non compliance with an airworthiness directive is a breach of a statutory duty and can lead to enforcement action including suspension or cancellation of an airworthiness certificate or an aircraft’s registration. Each directive in Schedule 1 addresses a specific unsafe condition or airworthiness limitation on Airbus A319, A320 or A321 series aeroplanes. The instrument itself does not specify the unsafe condition or the required action; it merely lists the AD name and number.

Revocation and remaking. This is a legal technique used where an existing instrument is revoked and simultaneously remade in identical terms to cure a procedural defect, update the legal basis, consolidate multiple amendments, or forestall a sunsetting event. Under subregulation 39.001(1), CASA’s delegate has power both to issue new airworthiness directives and to revoke existing ones. By doing both in one instrument, continuity of obligation is maintained: the duty to comply never ceases because the remade directive takes effect at the moment the old one ceases. The instrument’s note confirms that each remade directive is in “exactly the same form as appears in the latest published edition of the Directive.” This ensures the textual content is unchanged even though the legal parentage is refreshed. The “latest published edition” refers to the most recent version of that directive that CASA had published prior to 20 December 2004. Any amendments made after that date are not captured by this instrument, so later revisions would need a subsequent remake or a separate amending instrument.

Delegate authority. The instrument is signed by David Alan Villiers as delegate of CASA. Subregulation 39.001(1) authorises CASA or its delegate to issue airworthiness directives. The instrument recites that the delegate is acting under that provision. The signature block includes a small image, possibly a seal or stamp. The instrument does not indicate whether the delegate had any internal authorisation instrument or delegation register reference, but that is typical for such instruments. The legal effect does not depend on recording the precise delegation chain as long as the authority exists in fact.

Schedule 1. This schedule is the core of the instrument. It lists each airworthiness directive by its common name (e.g., “Artus Transformer Rectifiers”) and its alphanumeric AD number (e.g., “AD/A320/1”). Some entries include an amendment number (e.g., “Amdt 2”, “Amdt 4”), indicating that the latest published edition of that directive incorporates prior amendments. Several entries are marked “CANCELLED.” The instrument does not explain what “CANCELLED” means in this context. It could mean that the underlying unsafe condition has been resolved and the directive is no longer in effect, or it could mean that the directive has been superseded by another AD or by an airworthiness limitation item. The inclusion of cancelled directives in the revocation and remake suggests that the instrument treats them as still existing in cancelled form, perhaps to formally revoke and replace them with an explicit “no requirement” instrument. This is a potential source of confusion for operators who see a cancelled AD on their compliance list: they must determine whether the remade cancelled directive imposes any residual duty (e.g., a one time inspection that has already been completed and thereafter no further action). The safest approach is to treat a cancelled AD as having no continuing mandatory action, but the instrument does not state that explicitly.

Attached instruments. The delegate’s note says “each attached Airworthiness Directive is being re-made in exactly the same form.” The instrument therefore does not stand alone; each directive is a separate attached document. These attachments are not reproduced in the source provided, but a complete compliance analysis would require accessing each attached instrument. The remade directives were presumably published alongside the revocation instrument in the Federal Register of Legislation or in CASA’s own AD database. For lawyers and compliance professionals, the practical implication is that this instrument is not self contained; it is a gateway document that points to the actual obligations. Any legal advice about an operator’s duties must identify which specific ADs apply to the aircraft in question and then locate the remade directive for that AD. The instrument’s function is to confirm that the remade directive is currently in force and that the operator cannot argue that the earlier version lapsed or was improperly made.

The instrument directly affects any person or organisation that operates, maintains, owns, or leases an Airbus A319, A320 or A321 series aeroplane registered in Australia, or any foreign registered aircraft operating into Australia that must comply with Australian airworthiness directives under bilateral agreements or operational rules. The primary duty holders are the registered operator of each aircraft and the maintenance organisations that carry out work on those aircraft. Under CASR 39.003, an operator must ensure that each applicable airworthiness directive is complied with in accordance with its terms. That duty extends to ensuring that inspections, modifications, replacements, and record entries are performed on time and correctly. The instrument does not create new duties but it does confirm that all the listed directives remain legally enforceable from the date of remake.

Operators and owners. Australian Air Operator Certificate holders and private owners of A320 family aircraft must include each applicable remade directive in their continuing airworthiness management system. They must check that their maintenance program references the correct AD number and amendment level as at 20 December 2004. Any directive that was previously complied with using a later amendment (post December 2004) may need to be reassessed if CASA later revised the directive after this remake. However, the instrument itself does not affect later amendments; it only remakes the directives as they stood at the latest published edition before the remake date. Operators who relied on amendments issued after 20 December 2004 should verify that those amendments were properly made under the then current legal framework; if not, the remade directive might be the controlling version.

Maintenance organisations. Part 145 maintenance organisations and authorised persons who perform work on A320 series aeroplanes must ensure that their technical data, work instructions, and component tracking systems refer to the correct AD versions. The instrument’s revocation and remaking could cause confusion if a maintenance manual or engineering order cites the old revocation date or the pre remake instrument number. Organisations should update their records to reflect that the directive is now a fresh instrument, even though its content is unchanged. This is especially important for tracking repetitive inspections where the due date may be tied to the original directive’s effective date; the remake does not reset the compliance clock unless the directive itself says otherwise.

CASA and aviation regulators. CASA itself is affected as the issuer and enforcer. The delegate has used this instrument to regularise the legal status of a large block of directives. The instrument allows CASA to take enforcement action under the remade directives without having to defend the validity of the earlier version against procedural objections. For other regulators (e.g., EASA, FAA), the instrument may be relevant when harmonising airworthiness requirements or when recognising Australian ADs for aircraft imported into or exported from Australia. Because the instrument is purely domestic, it does not affect the legal force of equivalent directives issued by other authorities, but operators with international exposure must comply with both sets of requirements if they overlap.

Lessors and financiers. Entities holding security interests in A320 aircraft should be aware that the remade directives are mandatory and that failure to comply could affect the aircraft’s airworthiness certificate and therefore its value. Finance documents often require the operator to maintain the aircraft in an airworthy condition and to comply with all applicable airworthiness directives. This instrument does not change that obligation, but it does eliminate any argument that a directive had sunset or was invalid, thereby strengthening the lessor’s ability to demand compliance.

Manufacturers and design approval holders. Airbus Industrie and its suppliers may be indirectly affected because the remade directives reference their products and may require modification or replacement of parts. The instrument does not impose any duty on manufacturers directly, but they must continue to support the affected modifications, service bulletins, and spare parts to enable operator compliance. The remake does not alter the technical content, so no new design changes are required.

The instrument itself does not enumerate specific duties; those are contained in each remade airworthiness directive. However, the general duties flowing from the instrument can be derived from the CASR framework. Under subregulation 39.003(1), the registered operator of an aircraft must ensure that each applicable airworthiness directive is complied with. This duty applies to all directives listed in Schedule 1 that are not cancelled (and even for cancelled directives, the operator may still have a record keeping duty, but no further operational action). The duty includes: performing the required action within the compliance time (which may be a calendar time, flight hours, or cycles), using approved data and procedures, making proper entries in the aircraft’s maintenance records, and retaining those records for the period specified in the regulations. The operator must also ensure that any modification, replacement, or inspection is carried out by an appropriately authorised person in accordance with the applicable maintenance data.

Right to alternative means of compliance. The CASR regime generally permits an operator to apply to CASA for an alternative means of compliance with an airworthiness directive if the alternative provides an equivalent level of safety. This instrument does not affect that right. The remade directives themselves may contain provisions for alternative methods or for extensions of compliance times with CASA approval. An operator who wishes to deviate from the directive must seek approval; the instrument does not grant any blanket exemption. The right to apply for an exemption under regulation 11.030 of the CASR also remains available.

Right to challenge the directive’s validity. The instrument is a legislative instrument made under a head of power. An operator could theoretically challenge the validity of the remake on administrative law grounds, such as unreasonableness or procedural error, but the instrument’s content is purely housekeeping, and any challenge would face a high threshold. The instrument does not confer any express right of review beyond what general administrative law provides.

Duty to maintain currency. Because the instrument remakes the directives as of 20 December 2004, operators must be aware that later amendments or replacements may have been issued after that date. The duty is to comply with the applicable directive as it stands from time to time. If CASA later amends one of these directives (by a separate instrument), the operator must comply with the amended version. The instrument does not freeze the directive at the 2004 version; it merely rescues that version from potential sunsetting. Future amendments are independent.

Record keeping duties. CASR requires that compliance with airworthiness directives be recorded. The remake does not change the record keeping obligations. Operators should ensure that their records reflect the AD number and amendment level as remade, and that the action taken references the remade instrument (e.g., by quoting the delegate’s instrument number, if available). This is particularly important if the previous records cited an older revocation date that no longer exists.

Duty of maintenance organisations. Authorised maintenance organisations have a duty under their approval to perform work in accordance with approved data. A remade directive remains approved data. Organisations must not deviate from it without approval. They also have a duty to report any failure to comply or any defective condition they find during the directive’s performance. The instrument does not alter these duties.

Rights of third parties. Third parties, such as lessors, insurers, and passengers, do not have direct duties under the instrument but may have contractual rights triggered by non compliance. For example, an insurance policy may exclude cover if the aircraft is not airworthy due to an un complied AD. The instrument’s confirmation that the AD is in force supports a claim by a lessor or insurer that the operator failed in its obligation. Similarly, a passenger injured in an accident caused by a known non compliance could use the remade directive as evidence of the operator’s breach of duty of care.

The instrument itself does not prescribe penalties; penalties for non compliance with airworthiness directives flow from the Civil Aviation Safety Regulations and the Civil Aviation Act 1988. Under CASR 39.003, an operator who fails to comply with an applicable airworthiness directive may be subject to an infringement notice, a civil penalty, or criminal prosecution, depending on the severity and circumstances. The maximum penalty under the Act for a breach of a safety regulation can be substantial, including fines of up to several hundred thousand dollars for individuals and millions for corporations. In practice, CASA often uses administrative action first, such as issuing a direction to ground the aircraft or suspending the operator’s certificate until compliance is shown. The existence of this revocation and remaking instrument strengthens CASA’s enforcement position because it removes any argument that the directive had expired or was procedurally invalid.

Enforcement actions available. CASA can issue a notice of proposed suspension or cancellation of an airworthiness certificate under regulation 21.195 of CASR if an aircraft is not in compliance with applicable airworthiness directives. It can also issue a direction under regulation 39.005 requiring immediate grounding. For serious or repeat non compliance, CASA may refer the matter to the Commonwealth Director of Public Prosecutions for criminal prosecution. The instrument’s clear statement that each directive is remade with full legal force makes it harder for an operator to argue that it did not know of the obligation or that the obligation was not properly imposed.

Acceptable means of compliance. If an operator follows an alternative means of compliance approved by CASA in writing, that is treated as compliance. Without such approval, the operator must follow the directive exactly. The instrument does not affect the availability of alternative means. Enforcement officers will look at the operator’s records to verify that the required action was performed and that any deferral or extension was properly authorised.

Liability of maintenance organisations. A maintenance organisation that performs work that does not comply with the directive may also face enforcement action, including suspension of its certificate. The instrument does not directly impose duties on the organisation, but the organisation’s own procedures must incorporate the directives. If an organisation signs off an aircraft as airworthy without ensuring compliance with all applicable ADs, it may be liable under regulation 42.100 or similar provisions.

Defences. A possible defence to non compliance could be that the directive was impossible to comply with due to lack of parts or operational necessity, but CASR generally requires the operator to apply for an extension or exemption before the compliance date. The instrument does not provide any statutory defence. An operator who knowingly operates an aircraft in breach of an AD commits an offence under the Act, with potential strict liability elements.

Record of enforcement. The source does not mention any specific enforcement actions taken against operators of A319/A320/A321 aircraft for non compliance with these particular directives. However, the fact that CASA went to the trouble of revoking and remaking the entire block suggests that at least some of these directives had been the subject of legal uncertainty or administrative difficulty. It is plausible that CASA wanted to ensure a watertight enforcement basis for the future. Analysts should expect that, following this instrument, CASA inspectors will treat the remade directives as requiring strict compliance.

Interaction with other regulators. Because these directives apply to a common Airbus family, operators flying into FAA or EASA regulated airspace may also be subject to equivalent directives from those authorities. Compliance with an Australian AD alone does not guarantee compliance with an overlapping foreign AD. Enforcement by CASA is independent of foreign enforcement.

Civil Aviation Safety Regulations 1998 (CASR). The instrument is made directly under CASR 39.001(1). It sits within Part 39 of CASR, which governs airworthiness directives. Part 39 (as it stood in 2004) operates together with Part 21 (certification of aircraft and components), Part 42 (continuing airworthiness), and Part 145 (maintenance organisations). A remade directive is a mandatory continuing airworthiness requirement. Compliance with the directive may also affect the validity of a certificate of airworthiness under regulation 21.175, which requires the aircraft to conform to its type design and be in a condition for safe operation. An un complied directive means the aircraft may not be in a condition for safe operation, potentially invalidating the certificate.

Civil Aviation Act 1988. The Act provides the overarching statutory framework for aviation safety. Section 20A of the Act authorises CASA to issue airworthiness directives. Contravention of a directive may constitute an offence under section 20A(5) or under regulations made under the Act. The instrument does not amend the Act, but it relies on the Act’s delegation and penalty provisions.

Air Navigation Act 1920. Some older airworthiness instruments were made under this Act. The instrument in question is made under CASR, not the Air Navigation Act, but it may interact with foreign recognition provisions. For example, a foreign registered aircraft operating into Australia may be required to comply with Australian airworthiness directives under the Air Navigation Regulation or bilateral agreements. The instrument confirms the existence and validity of the directives for that purpose.

Work Health and Safety Laws. Aircraft operators also have duties under workplace health and safety legislation to ensure a safe working environment. Compliance with airworthiness directives is part of discharging that duty. A breach of an AD could be used as evidence of a failure to ensure health and safety.

Contract and tort law. As mentioned under duties and rights, contractual clauses often require compliance with all applicable ADs. A failure to comply may put the operator in breach of contract with lessors or financiers, potentially triggering repossession or acceleration clauses. In tort, if a non compliance causes injury or damage, the remade directive provides a clear standard of care. The instrument itself does not create a private right of action, but it can be used to establish what a reasonable operator ought to have done.

International standards. The Chicago Convention on International Civil Aviation and Annex 8 (Airworthiness of Aircraft) require Contracting States to issue mandatory continuing airworthiness information. The instrument is consistent with Australia’s obligations under Annex 8. It does not conflict with FAA or EASA requirements, but if a component is subject to both an Australian AD and a foreign AD, the stricter requirement must be followed. The instrument does not harmonise the directives with foreign equivalents; it only ensures Australian legal continuity.

Other airworthiness directives. The instrument revokes and remakes only the listed directives. It does not affect any other airworthiness directive for these aeroplane models that may have been issued before or after 2004 but that is not listed. For example, if a directive was issued for the A320 in 2005 (after this instrument), it would be separate. The instrument also does not affect any airworthiness directive for other aircraft types or for other models (e.g., A318 or A330). Operators must ensure they have a complete list of all applicable ADs, not just those in this instrument.

Federal Register of Legislation. The instrument is a legislative instrument and should have been registered on the Federal Register of Legislation (formerly the Federal Register of Legislative Instruments). Its registration provides public notice and the date of effect is the date of registration or the date specified in the instrument (20 December 2004). Since the instrument remakes the directives, the remade directives took effect on that date unless a later date is specified in each attached directive. However, the instrument does not state a later date, so the effective date is likely the date of signing or registration. Operators were required to comply from that date, but if they were already compliant with the earlier version, no action was required.

This instrument is a single instrument and has not itself been amended (within the source provided). The source states it was made on 20 December 2004. There is no indication of any subsequent amending instrument that modifies this revocation and remaking. Therefore, the instrument stands as originally made. However, the schedule entries include amendment numbers for many of the underlying directives (e.g., AD/A320/4 Amdt 2, AD/A320/8 Amdt 1, AD/A320/11 Amdt 1, and so on). These amendment numbers refer to prior revisions of each directive that were incorporated into the “latest published edition” before the remake. For example, AD/A320/12 has “Amdt 1”, meaning that when CASA remade that directive in December 2004, the version used already contained Amendment 1. The instrument does not disclose the content of those amendments or when they were made. Operators needing the full technical history of a particular directive would need to consult CASA’s records to trace each amendment back to its original effective date. The instrument’s effect is to start a new legal life for each directive, but the technical compliance dates and action requirements are those of the latest published edition, which includes all prior amendments.

Some entries are marked “CANCELLED” together with an amendment number (e.g., AD/A320/16 Amdt 2 “CANCELLED”, AD/A320/31 “CANCELLED”, etc.). The cancellation itself may have been effected by a prior amendment. For example, AD/A320/16 Amdt 2 is marked as cancelled; Amendment 2 presumably cancelled the directive. When the instrument remakes that directive, it presumably remakes the cancelled version, meaning the directive continues to exist but in cancelled state. That is an unusual situation: a cancelled directive that remains on the books. The practical effect is that no further action is required for that AD, but the operator retains a record that it was formerly applicable. The instrument does not consolidate or remove cancelled directives; it keeps them in legal existence. This could be a trap for compliance software: a system that automatically loads all ADs from the index might include cancelled ones and treat them as requiring action unless the operator programs an exception for “CANCELLED.”

The instrument also contains entries with multiple amendments (e.g., AD/A320/46 Amdt 4). This indicates that the directive had been amended four times before the remake. The remake does not change the amendment level; it simply incorporates all four amendments into the remade version. Any future amendment after December 2004 would be a separate instrument.

For an analyst assessing the current legal status of any particular directive, the amendment history after 2004 is unknown from this source. The instrument is historical; it may have been superseded by later instruments that revoked or replaced these directives again. Without researching CASA’s current AD database, one cannot assume that the remade directives are still in force today. They almost certainly have been further amended, revoked, or consolidated into airworthiness limitation items or other documents. The deep dive must note this limitation.

The instrument’s own amendment history is nil, but the history of the underlying directives is embedded in the amendment numbers. The delegate’s note says the remade directive is in the same form as the “latest published edition.” That edition would have included all amendments up to the date of publication. If a later edition was published between the date of the “latest published edition” and the date of the instrument (20 December 2004), there could be a discrepancy. The instrument is likely to have used the edition published closest to the signing date.

The source provided contains no reference to any litigation. There are no case names, court decisions, tribunal rulings, or reported disputes concerning this instrument or any of the listed airworthiness directives. This is expected for a routine administrative instrument. Airworthiness directives are frequently the subject of disputes between operators and CASA, but those disputes rarely result in published court decisions. They are more often resolved internally or through the Administrative Appeals Tribunal. Any litigation involving these specific directives would likely have occurred after 2004 and would not be captured in this 2004 instrument. A search of Australian aviation case law might reveal decisions on related ADs, but the instrument itself gives no hint.

It is possible that the revocation and remaking was motivated by a legal challenge or the threat of one. An operator may have argued that an earlier directive was invalid because it was not properly made, or because it had expired under sunsetting provisions. The remaking would moot such a challenge. However, without source evidence, this remains speculation. The analyst should not assert litigation that is not mentioned.

The instrument’s mention of “CANCELLED” directives could imply that some directives had been litigated and found to be unnecessary or overbroad, but cancellation is also common when a design fix is incorporated into the type design. No court is named.

For a legal professional advising a client, the lack of litigation history is notable but not surprising. The legal risk lies not in the validity of the instrument itself but in the operator’s failure to comply with the underlying requirements. If an operator wants to challenge an AD, it would usually apply to CASA for an alternative means of compliance or seek review of CASA’s refusal. That review may go to the AAT or the Federal Court, but the instrument’s role would be limited to proving that the AD exists. The instrument provides a clean chain of title for the AD, which would make it harder to argue that the AD was not lawfully made.

In summary, there is no litigation history to report from the source. The deep dive should state that clearly rather than inventing cases. The user expects accuracy, not padding.

Several traps in this instrument are not obvious at first reading.

1. Cancelled directives included but not flagged as obsolete. The schedule lists directives with “CANCELLED” in the name column, yet the instrument revokes and remakes them as if they are active. A compliance officer who sees “AD/A320/16 Amdt 2” on a tracking list might believe it requires action, especially if the tracking system does not parse the word “CANCELLED.” The remade instrument for a cancelled directive may contain language such as “This directive is cancelled” or may be entirely blank. The instrument does not clarify whether a cancelled directive imposes any residual record keeping duty. The safe approach is to treat a cancelled directive as having no further mandatory action, but the operator must confirm that any recurrent inspections required by a prior version have been properly terminated. The risk is that an operator stops acting on a cancelled directive without verifying that a successor directive has taken its place.

2. “Latest published edition” ambiguity. The note says each remade directive is in exactly the same form as in the latest published edition. But what if two editions were published on the same day? Or what if the “latest published edition” was a draft or a version that had not yet been formally released? The instrument does not define “latest published edition.” In practice, CASA officers know which edition was current, but a third party relying on the instrument may not. If a discrepancy emerges between the remade directive and a later discovered earlier edition, the remade version prevails because it is the fresh legal instrument. However, if CASA mistakenly remade an outdated edition, operators could be exposed to a different requirement. The safest course is to obtain a copy of the remade directive from CASA’s official publication and rely on that version.

3. Amendment numbers embedded in AD numbers. Many entries include an amendment number (e.g., “AD/A320/4 Amdt 2”). The instrument remakes that specific amended version. If an operator had already complied with an earlier amendment of that directive (e.g., Amdt 1), they might have satisfied the requirement only if Amdt 2 did not add new actions. But the instrument does not help determine whether later amendments are retroactive or prospective. Operators need to compare the remade version with their compliance records.

4. No compliance dates or actions listed. The instrument is entirely silent on what each directive requires. An operator cannot know from this instrument alone whether a given AD is a one time inspection, a repetitive check, a modification, or a life limit. The practical gotcha is that a busy operator might think the instrument is merely administrative and ignore it, only to find that their maintenance program is out of date because the remade directive changed a compliance time (but the instrument says it is identical, so that should not happen). Still, the instrument is a reminder that each directive must be actively managed.

5. Relationship between this instrument and later CASA actions. This instrument remakes the directives as of December 2004. CASA may have later reissued, renumbered, or consolidated these directives. For example, the AD/A320 series may have been superseded by a new numbering system (e.g., AD/A320/xxx). An operator who only searches by the old number might miss the current requirement. The instrument does not contain a sunset clause or a review date, so it continues indefinitely unless later instruments modify or revoke it. However, many of the specific ADs may have been withdrawn or replaced by later design changes (e.g., the manufacturer issued a service bulletin that was incorporated into the type design). The instrument does not track that.

6. Signature image may be illegible. The instrument includes an image placeholder “image.001”. In a printed version, the delegate’s signature appears. In an electronic version without the image, the instrument may appear incomplete. This could cause evidentiary problems if the instrument’s authenticity is challenged. However, the instrument was likely registered and published, so the original signed copy would be held by CASA.

7. Potential for double counting. Because the instrument revokes and remakes each directive, an operator might mistakenly think that a new compliance due date starts from the remake date. Unless the directive itself resets the compliance interval, the due dates remain unchanged. For example, if a directive required an inspection “within 1000 flight hours after the effective date”, the effective date was originally the date of the first issuance of that directive (or the latest amendment). The remake does not reset that clock. The instrument does not mention this, so operators must check the original compliance language.

8. Foreign registered aircraft. Operators of foreign registered A320 family aircraft that are wet leased into Australia or operate under a foreign operator permit may be required to comply with Australian ADs. The instrument applies to any aircraft subject to CASR. The gotcha is that such operators may not have systems to track Australian specific ADs and may rely on FAA or EASA directives, which may differ. The instrument does not exempt foreign operators.

9. No transitional provisions. The instrument does not provide any grace period for compliance. It takes effect from the date of signing (20 December 2004) or registration. If an operator had scheduled a maintenance action for early January 2005 under the old version, they are still compliant as long as the action was within the compliance time. But if the action was overdue, the remake does not excuse past non compliance.

Compliance with this instrument is best understood as compliance with the entire package of remade airworthiness directives. The instrument itself requires no separate action; the obligations arise from each attached directive. Therefore, the steps below focus on ensuring that all applicable directives are properly integrated into the operator’s continuing airworthiness management system.

Step 1: Identify applicable directives. The operator must obtain a list of the airframes in their fleet that are A319, A320, or A321 series. For each aircraft, determine which ADs from Schedule 1 apply. Applicability is determined by the effectivity of each directive, which is stated in the directive itself (e.g., by serial number, manufacturer’s block, or design standard). The instrument does not provide effectivity; the operator must read each remade directive. Directives marked “CANCELLED” need not be complied with, but the operator should record that they were considered and found to be cancelled to avoid future audit questions.

Step 2: Obtain the authentic text of each remade directive. The instrument states that each attached directive is remade in the same form as the latest published edition. The operator should obtain a copy of the remade directive from CASA’s official AD database or from the Federal Register of Legislation. Do not rely on third party summaries or pre remake versions. The remade directive may have a different instrument number. The operator should store the instrument number and date of the remade directive in their compliance records.

Step 3: Compare with current compliance status. For each directive, check the aircraft’s maintenance records to see if the action has already been performed. If the directive requires a one time action and it was already completed, no further action is needed, but the record should reference the remade directive to confirm compliance. If the directive requires repetitive actions, ensure that the next due date is correctly calculated based on the original compliance time (not the remake date). If the directive requires an action that has not yet been performed, schedule it within the remaining compliance time.

Step 4: Update maintenance program. Include each applicable directive in the operator’s maintenance schedule or airworthiness limitations section. Ensure that the directive’s number, amendment level, and compliance window are clearly stated. The maintenance program should be approved by CASA or by an approved continuing airworthiness management organisation.

Step 5: Train personnel. Engineers, maintenance planners, and quality assurance staff should be made aware that the directives have been remade. They should understand that the legal basis has changed but the technical content is identical. Any confusion about “latest published edition” should be resolved by consulting the remade instrument directly.

Step 6: Monitor for future changes. The instrument itself is static, but the ADs may be further amended or replaced. Operators must have a process to track CASA’s issuance of new directives or amendments. Because the instrument does not consolidate future changes, it is the operator’s responsibility to ensure that the version held is current. This is especially important for directives that are revised after December 2004.

Step 7: Handle cancelled directives appropriately. For each cancelled directive, the operator should maintain a record that the directive is no longer in effect and that no further action is required. However, if the cancelled directive previously required a one time action, ensure that the action was performed. If the cancelled directive was part of a series (e.g., superseded by another AD), ensure compliance with the superseding directive.

Step 8: Verify alternative means of compliance. If the operator has previously obtained CASA approval for an alternative means of compliance with a directive that was remade, that approval should still be valid because the technical requirement has not changed. However, the operator should confirm with CASA that the approval remains effective under the remade instrument. It may be prudent to request a new approval letter referencing the remade directive.

Step 9: Audit compliance. Internal audit programs should verify that all applicable directives are covered and that the records reflect the remade instrument. An auditor will look for the instrument’s date and number in the records. Lack of reference to the remade instrument may be cited as a finding, even if the technical compliance was correct.

Step 10: Seek professional advice if uncertain. Given the volume of directives and the potential for ambiguity (e.g., cancelled directives, amendment levels), an operator should engage an aviation legal specialist or a CASA approved continuing airworthiness management organisation if they are unsure of any directive’s applicability or compliance status. The instrument does not provide a compliance checklist; professional judgement is required for each directive.