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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 Most IA's will not sign off an annual on an aircraft with an out-of-date hydro.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 |
#2
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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. -- Change "netto" to "net" to email me directly Eric Greenwell Washington State USA www.motorglider.org |
#3
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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 |
#4
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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. -- Change "netto" to "net" to email me directly Eric Greenwell Washington State USA www.motorglider.org |
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