Thank you very much for your responses and opinions.
I think it was a little mistake to mix the Pans ops regulations with a FAA chart, because both regulations are slightly differents. But, imagine that this chart was from an european airport. I'm pretty sure there are any similar approach in Europe. Would be different your opinions?
I specially interested in to know how do you interpret that note in the Pans Ops doc 8168:
3.2.3.2 Entry into a racetrack procedure:
.........
Note.— Racetrack procedures are used where sufficient distance is not available in a straight segment to
accommodate the required loss of altitude and when entry into a reversal procedure is not practical. They may also be
specified as alternatives to reversal procedures to increase operational flexibility (in this case, they are not necessarily published separately).
Could we in this case use a 2 min racetrack over the ndb to descend to 2000' (outbound leg), intercepting final course and descending to MDA or we must proceed outbound and make the reversarl procedure depicted in the chart?
I have read in a intrument flying technique book (FAA based) that explain that you could do that reversal racetrack over the NDB, but I'm not sure if Pans Ops regulations agree with that. Any suggestion?