At 18:06 07 February 2006, Eric Greenwell wrote:
Gary Evans 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sign off an annual on an aircraft with an out-of-date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?

I'm under the impression that the cylinders we use
in our gliders are
NOT classified as aircraft components, but are, instead,
considered
'portable' equipment. To be aircraft components, the
glider would have
to be certified with an oxygen system, and none of
them are. What we do
is (I believe) no different than the airplane pilot
that carries on a
cloth bag with the cylinder and regulator in it, then
uses the seat belt
to strap it down next to him. In other words, our gliders
do not have
oxygen systems in them, just carry-on baggage that
happens to be an
oxygen system.

If true, then the cylinders have to meet the regulations
for carrying
these cylinders around in cars, busses, etc, which
would be DOT
regulations.


--
Change 'netto' to 'net' to email me directly

Eric Greenwell
Washington State
USA

www.motorglider.org


There seems to be consensus (FAA included) that DOT
regs do not apply to a 02 cylinder in an aircraft so
what about in your car? As I read DOT regs on pressure
cylinders they apply to cylinders in transportation
in commerce. The definition of commerce is 'the exchange
or buying and selling of commodies on a large scale
involving transportation from place to place.'
Transporting your own 02 cylinder would not fit this
definition.
Am I missing something? I still haven't found a reg
that makes it illegal to fill your personal non-DOT
02 cylinder.