Airbus SAS Office of Airworthiness

We would like to highlight our concerns over the fact that the FAA have introduced Modification 36734, SB 28-1153 and any associated AMOCS as a terminating action to the AD. This modification and associated SB was the terminating action for the original AD however any pump modified as such was two way interchangeable with a pump with a part number terminating in 005, 002 or 001. Therefore any aircraft having accomplished mod 36734 or SB 28-1153 could potentially have a pump with a part number terminating in 005, 002 or 001 installed. Mod 37508 and SB 28-1159 were introduced not only to enlarge the applicability but also to update the interchangability of 05R pumps with previous standards. Mod 37508 and SB 28-1159 are the only means to ensure that no impacted pumps are on the aircraft. We understand that the FAA does not wish to impose the operating restrictions on unaffected operators however by allowing operators to carry out an inspection other than that in SB 28-1159 Airbus are not able to update the operator?s AFM. Therefore the TR will remain in the operator?s AFM even though they are not operating with impacted pumps. We would like to highlight that SB28-1159, for operators with pumps with part numbers other than those given in the AD, requests no action other than to record the accomplishment of the SB. This then allows the AFM TR to be removed from the AFM. In our experience operators do not wish to apply this procedure and those not impacted will accomplish the SB immediately. Without accomplishment of SB 28- 1159 the AFM TR will remain in the operators AFM. Please also note that TR 4.03.00/28 issue 02 dated May 18 2007 replaced TR 4.03.00/28 dated May 4 2006 which is no longer in circulation.