O2 cylinder

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sign off an annual on an aircraft with an out-of-date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.


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Eric Greenwell
Washington State
USA

www.motorglider.org

You are CORRECT
tim
Wings & Wheels
www.wingsandwheels.com



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.


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Eric Greenwell
Washington State
USA

www.motorglider.org

Eric Greenwell wrote:

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.

This MAY not be true. The FAA reference in Sect 3(Guidance), para D(4)
says:
Any cylinder that is part of a supplementary oxygen system,
that in the course of its normal operation is gradually
depleted, may remain in service if it meets the operational
requirements in 14 CFR § 91.211, Supplemental oxygen.

I would have thought that the oxygen systems we use in gliders are the
same conceptually as the portable cylinders carried on most commercial
airliners for crew use in the event of a decompression. I thought (but
could be wrong) that these were "supplementary oxygen systems"? If so,
DOT markings are unnecessary. I flew with an airline for some years but
I don't recall seeing DOT marked on any of the portable cylinders on the
flight deck.

...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.

I'm not sure about that. If we forget how it came into your possession,
the FAA reference in 2(Background) says:

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.

That seems to me to imply that carriage as a supplementary oxygen system
in an aircraft does not qualify as "transportation in commerce". Again,
DOT regs would be inapplicable.

I recall once that a request from our navigators to have a pencil
sharpener clamped to the edge of their table was refused because that
would "install it" in the aircraft. Drawings would have to be drawn,
stress calculations made, Engineering Orders would have to be approved.
A maintenance schedule would need to be developed, transit
qualifications and MELs would have to be considered. I think they were
each issued with pocket sharpeners.

Bush lawyer anybody?

Graeme Cant

Graeme Cant wrote:

I'm not sure about that. If we forget how it came into your possession,
the FAA reference in 2(Background) says:

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.

That seems to me to imply that carriage as a supplementary oxygen system
in an aircraft does not qualify as "transportation in commerce". Again,
DOT regs would be inapplicable.

I think "cylinders used as components in aircraft" refers to built-in
oxygen systems, not the portable, carry-on, systems used in gliders and
the smaller general aviation aircraft. I know it looks like our
cylinders are "components" because there is a mounting hole and strap
for the cylinders, but without an oxygen system certification as part of
the glider, that hole is just another baggage space.

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Change "netto" to "net" to email me directly

Eric Greenwell
Washington State
USA

www.motorglider.org