At 17:12 07 February 2006, Hl Falbaum wrote:


--
Gary Evans' wrote in message
...
At 22:12 06 February 2006, Jphoenix wrote:

Here's the current FAA guidance on the subject: (HBAW
02-01B)
http://www.faa.gov/library/manuals/e...ors/8300/hbaw/

2002/

An excerpt below, but please read the whole bulletin
in the link above
as this policy should not be taken out of context.
Most IA's will not
sign off an annual on an aircraft with an out-of-date
hydro.

'C. Title 49 CFR parts 171 through 180, Hazardous Materials
Regulations
(HMR), pertains to the retest and inspection of cylinders
in
transportation in commerce. However, cylinders used
as components in
aircraft are not considered to be in transportation
in commerce when
installed in an aircraft. As a result, the retest period
for cylinders
used as a component of and installed in an aircraft
is not subject to
the HMR. However, 49 CFR part 180, =A7 180.205, formerly
part 173, =A7
173.34(e), would apply to a cylinder that is removed
from the aircraft
and offered for transportation as an article of commerce.
In this case,
the cylinder must include the appropriate exterior
packaging and hazard
communication requirements (i.e., shipping papers,
marking, and
labeling).'

Jim



Two observations.

1) This bulletin appears to apply only to type certified
aircraft.
2) Section 1,3,C,3 shown below only requires that
non-DOT
cylinders must be tested as per DOT specifications.

'All other cylinders must be inspected and tested
as
required by subparagraph 3C(1) above as it applies
to DOT 3HT cylinders unless alternative testing and
inspection procedures are specified by the manufacturer
or referenced authority'.

The bulletin also states that that existing dot requirements
do not apply to aircraft 02 cylinders which makes
me
wonder if DOT requirements are only for the transportation
of cylinders. Can anyone come up with the actual DOT
regulation that a non-DOT aircraft 02 cylinder cannot
be legally filled?




The legalities notwithstanding, is there a 'real' safety
problem with a
steel cylinder that is not retested ?

This is, after all, a life suppport system.

It seems clear that as long as the cyl is in the plane,
it is probably legal
to fill it

How safe is it? What is the probability of a good
looking 15 year old O2
cylinder failing a hydrotest?
If it fails is it by definition unsafe (technical
but not significant
failure) --could this happen?

Thanks

Hartley Falbaum




I didn't raise the question to determine if hydo testing
could be avoided. Everyone should have their tank tested
regardless of its DOT status, I did mine. I was rather
asking the question because most everyone assumes DOT
approval is required for legal filling and from what
I have read that point is at least questionable. I
had once tried to search for such a DOT requirement
with no luck so If anyone has the specific reg please
post it.