Review of legacy airworthiness directives unique to Australia
Overview
We are reviewing legacy Australian airworthiness directives (ADs) for general aviation (GA) aircraft.
We have prepared a policy framework that we will use to assess whether they can be repealed, modified or retained. We have also used the framework and identified an initial category of structural fatigue ADs for potential repeal and seek your feedback on those ADs.
Industry feedback has indicated that these structural fatigue ADs:
- are not the most suitable mechanism for managing the associated safety risks
- do not reflect a contemporary approach for managing ageing aircraft
- do not take account of how individual aircraft are used, maintained and stored.
Additionally, most of these ADs only allow ageing structures to be managed through full aircraft retirement - a restrictive option unpopular with industry.
What we are consulting on
We are seeking feedback on:
- the potential repeal of 18 structural fatigue ADs
- the policy framework we are using to assess whether these ADs remain appropriate, justified and proportionate
- a proposed CASA direction that aims to formalise existing continuing airworthiness responsibilities for ageing aircraft used in air transport operations.
Rationale for the review
There are over 150 legacy Australian ADs affecting general aviation aircraft below 5,700 kg that remain active and may have unique Australian requirements. These ADs were issued before regulatory reforms in 2009 introduced a more streamlined and internationally aligned approach to the management of ADs in Australia.
Before 2009, Australia did not accept foreign-issued ADs. Instead, CASA and its predecessors issued Australian ADs regardless of the State of Design of the aircraft or product. As a result, a large number of Australian ADs were created – some imposing uniquely Australian requirements, and others duplicating, or closely aligning with ADs issued by the aircraft State of Design.
Under today’s regulatory, policy and risk framework, many of these ADs would be unlikely to be issued in the same form or at all.
Consistent with the commitment set out in CASA’s General Aviation Workplan, we are reviewing the remaining pre-2009 unique Australian ADs. The objectives of this review are to reduce unnecessary regulatory duplication and ensure that any uniquely Australian requirements remain appropriate, justified and proportionate in today’s operating and regulatory environment.
The ADs will be reviewed in categories under the policy framework, with separate consultations undertaken for each category. This consultation represents the first in that process and is focused on the proposed repeal of certain uniquely Australian structural fatigue ADs. It is not expected to cover all structural fatigue ADs in force, and we anticipate at least one further consultation on the structural fatigue AD category. The next category of ADs that will be reviewed is expected to involve ADs relating to wing bolts on certain Beechcraft aircraft.
Policy framework
How to best treat legacy unique Australian ADs in the contemporary airworthiness policy and regulatory environment raises a range of policy issues and questions.
We have developed the policy framework to guide the review of categories of pre-2009 unique Australian ADs. The framework is a set of principles that focuses on:
- alignment with contemporary policy and regulation
- risk‑proportionate decision‑making
- external and operational impacts.
The framework will enable a structured assessment of the ADs and, together with industry feedback, ensure that all relevant factors are considered. It also provides transparency for industry, owners and operators by clearly setting out how CASA will conduct the review.
Structural fatigue ADs - proposal
The first category of ADs under review relates to structural fatigue. These ADs are becoming increasingly challenging for aircraft owners and operators as the Australian GA aircraft fleet continues to age.
Before 2009, CASA and its predecessors adopted a precautionary, predictive approach to structural fatigue. This resulted in the issue of ADs for specific aircraft models that set mandatory hour or cycle-based life limits on the airframe or key aircraft components (such as wings, wing spars, wing spar caps, struts, fuselage/cabin). These limits were based on certification data available at the time of acceptance in Australia and, in many cases, are unique to Australia.
Many of these ADs are now decades old and were issued without the benefit of subsequent global experience or advances in maintenance practices, inspection techniques and structural monitoring. Importantly, many of these ADs are not replicated or supported by the State of Design or the aircraft manufacturer, creating additional burden and uncertainty for Australian operators and owners with well-maintained aircraft approaching or at the life limits stated in unique Australian ADs.
CASA has identified 18 ADs in this category that impose uniquely Australian requirements. CASA proposes that these ADs be repealed unless there is a clear evidence base to support their retention. Repealing these ADs would:
- help modernise the management of ageing aircraft,
- reduce regulatory duplication, and
- better align Australia’s approach with contemporary airworthiness policy and international practice.
Structural fatigue Airworthiness Directives in scope
The following structural fatigue ADs are being considered for repeal:
- AD/BEECH 55/61 Amdt 2 Wing Fatigue Life Limitation 3/2003
- AD/BEECH 90/36 Amdt 1 Wing Structural Fatigue Limitation 5/79
- AD/BEECH 90/57 Amdt 4 Fuselage Fatigue Life Limitations 4/85
- AD/BEECH 90/58 Wing Fatigue Life Limitation 3/81
- AD/CESSNA 310/33 Amdt 2 Wing and Airframe 13/2006
- AD/CESSNA 320/19 Amdt 1 Wing and Airframe 10/95 *
- AD/CESSNA 340/32 Wing and Airframe 10/1995
- AD/CESSNA 400/40 Amdt 14 Wing and Airframe 13/2006**
- AD/CHA/15 Wing Front Strut Aerobatic Fatigue Life Limitation 4/76
- AD/DHC-2/10 Amdt 8 Lift and Strut Attachment Fittings 3/88
- AD/FA-200/17 Amdt 1 Aerobatic Fatigue Life Limitation NK
- AD/FU 24/58 Amdt 1 Wing Structural Fatigue Life Limitation 6/2000
- AD/MSR/26 Wing Structural Fatigue Life Limitation 3/80
- AD/PA-23/66 Amdt 2 Wing and Structural Fatigue Limitation 12/1989
- AD/PA-28/58 Wing Structural Fatigue Life Limitation 12/1976
- AD/PA-31/37 Amdt 11 Airframe Retirement Lives 3/2012
- AD/PA-34/45 Amdt 1 Wing and Airframe Retirement Lives 6/95
- AD/PA-36/6 Amdt 3 Wing Structural Fatigue Limitations 7/2000
Notes:
* This AD is not published by CASA as this series aircraft do not appear on the Australian Aircraft Register. However, the AD is in force and published on the Federal Register of Legislation.
** Although repeal of this AD is recommended, ongoing management of the fatigue issue remains necessary. Publication of FAA AD 2005-12-12 as an Australian AD is recommended to provide a more comprehensive and current approach by the State of Design (FAA) for addressing fatigue concerns applicable to these aircraft models.
Other structural fatigue Airworthiness Directives
We acknowledge there are other Australian pre-2009 structural fatigue ADs in force affecting GA aircraft under 5,700 kgs. These ADs reflect requirements derived from a State of Design AD or mandated by the manufacturer as an Airworthiness Limitation listed in the Aircraft Maintenance Manual or Aircraft Flight Manual.
These ADs do not have unique Australian requirements and are not included in the current proposal.
We will assess these ADs for inconsistencies and duplications and expect to consult in future on whether more ADs in the structural fatigue category could also be considered for repeal.
Alignment with international practice and expert knowledge
We will continue to rely on the National Aviation Authority (NAA) of the State of Design and the original equipment manufacturer (OEM) as primary sources of expertise on aircraft design, ageing and fatigue management.
International experience, including accident and defect data from larger fleets overseas and the response of State of Design NAAs to ageing aircraft issues, play a critical role in our continuing airworthiness requirements. Global harmonisation, alongside Australia’s ability to act where local circumstances and risks require it, ensures that the continuing operational safety of aircraft and products is managed most efficiently in the longer-term.
Safety is our priority
Aviation safety remains paramount. ADs are one element of a broader safety system, which includes certification standards, manufacturer instructions, maintenance programs and operational requirements. To deliver their intended safety benefit, it is important that ADs are necessary, relevant, up-to-date, and support compliance by not placing undue burden and cost on industry.
Owner and operator responsibilities do not change
Regardless of the outcome of this review, registered owners and operators continue to have legal responsibilities for continuing airworthiness of their aircraft and ensuring that the aircraft is fit for safe operation.
This includes complying with:
- Mandatory Instructions for Continued Airworthiness (ICA)
- In force ADs in Australia (including State of Design ADs published by CASA)
- CASA maintenance and operational requirements.
The potential repeal of these ADs does not remove or reduce these obligations.
Proposal: Air transport operations – ageing aircraft continuing airworthiness management
Consistent with our regulatory philosophy, CASA applies a risk based regulatory approach, with the highest safety priority given to commercial passenger transport operations.
Following the repeal of any fatigue ADs, CASA proposes to issue a direction requiring that ageing aircraft considerations be addressed in the continuing airworthiness management of aircraft used in air transport operations. Under this direction the registered operator would be required to have a system in place to monitor the aircraft manufacturer’s instructions for continuing airworthiness that relate to ageing aircraft safety, and take appropriate action as required.
CASA considers this direction emphasises an existing continuing airworthiness management responsibility of AOC holders for air transport operations
The following continuing airworthiness arrangements would be considered sufficient to meet the intent of the direction:
- compliance with the manufacturer’s maintenance schedule (i.e. maintaining the aircraft in accordance with the manufacturer’s instructions for continuing airworthiness)
- an approved system of maintenance that is being kept up to date by the operator, or
- an approved maintenance program under CASR Part 42.
Why your views matter
We are seeking feedback from owners, operators, maintainers and other stakeholders to help inform a balanced, risk‑based outcome.
Your feedback will directly inform our assessment and any next steps.
How to submit feedback
Please submit your comments on the proposal through the consultation hub using the survey link provided on this page.
If you are unable to provide feedback via the survey link, please email us at regulatory-program@casa.gov.au
Documents for review
All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:
- Policy framework: unique Australian Airworthiness Directives
- MS Word copy of online consultation for ease of distribution and feedback within your organisation.
What happens next
At the end of the response period, we will:
- review all comments received
- make responses publicly available on the consultation hub (unless you request your submission remain confidential)
- publish a Summary of Consultation which summarises the feedback received and outlines next steps.
Give Us Your Views
Audiences
- Aircraft maintenance engineers (AME)
Interests
- Aircraft engineer licensing
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