Retesting and filling oxygen tank.

On Wed, 02 May 2012 08:44:16 -0500, lynn wrote:


So how about it you legal beagles out there--just
how does an aircraft owner get their oxygen system serviced legally?


Lynn, OK. I'll bite. I don't think I'm a "legal beagle", but I am a bit
of an FAR-nerd, so I'll expose myself to collective ridicule and attempt
to answer your question completely.

The first question to ask (as others have pointed out) is whether your
oxygen tank is considered (legally) to be part of your aircraft or not.
If the tank is not listed in your operating limitations section as a piece
of required equipment, and has not been included in any subsequent 337
forms as something that is installed in the aircraft, then it is not part
of your aircraft. In general, if something is not part of your aircraft,
then the FAA does not care about who inspected it or how it was inspected.

If it is not installed as a part of the aircraft but is carried aboard the
aircraft, then it is "cargo." The FAA has regulations about carrying
oxygen cylinders as cargo, but these apply to inaccessible cargo areas of
transport-category aircraft. So, on a private, Part 91 flight the FAA
does not care about what type of oxygen tank you may have aboard.

On the other hand, the Department of Transportation (DOT) does have
regulations about the transport of compressed gas cylinders. I am not an
expert on DOT regulations, but to my knowledge these regulations are not
specific to aviation oxygen (as opposed to any other type of compressed
oxygen). Therefore, any place (dive shop, welding supply shop, etc.) that
is certified to test and inspect compressed gas cylinders according to the
DOT requirements should be able to inspect and test your cylinder.

There is nothing "illegal" or shady about this. It's a DOT regulation, so
any shop that meets DOT requirements (see below for discussion of these
requirements) can legally certify your cylinder (whether or not it's used
in aviation).

If (and I highly doubt that this is the case with your Pik 20) the oxygen
cylinder is required equipment, then the manufacturer would be obliged to
publish inspection criteria and servicing instructions, and then you'd be
obliged to follow these procedures. In the absence of any specific
guidance from the manufacturer, the Aircraft Maintenance Technician (e.g.
A&P or IA) performing maintenance or inspection of the oxygen system would
follow the FAA's procedures as outlined in AC 43.13-1B "Acceptable
Methods, Techniques, and Practices - Aircraft Inspection and Repair". In
Chapter 9 this Advisory Circular describes how an AMT should inspect and
service installed oxygen cylinders, to wit:

9-51. SERVICE OXYGEN CYLINDERS.
REQUIREMENTS (Ref 49 CFR 173.34 e,
16). Standard-weight cylinders must be hydrostatic
tested at the end of each 5-year period
(10 years if it meets the requirements in 49
CFR 173.34 e, 16). This is a Department of
Transportation (DOT) requirement. Thesecylinders
carry an ICC or DOT 3AA 1800
classification and are suitable for the use intended.
Lightweight cylinders must be hydrostatic
tested every 3 years, and must be retired from
service after 24 years or 4,380 pressurizations,
whichever occurs first. These cylinders carry
an ICC or DOT 3 HT 1850 classification and
must be stamped with the approval after being
inspected. (Ref. 49 CFR 173.34 e, 15).

Note that the FAA's guidance refers to 49 CFR which is the Transportation
code. The rules in 49 CFR 173.34 are pretty long, but your question
concerned who can do this inspection, not necessarily how it is done, so
I'll dispense with quoting the "how" and focus on the "who". 49 CFR
173.34 (e) (2) (i) says:"

"No person may mark a cylinder with a test date or retester identification
number,or otherwise represent that a DOT specification or exemption
cylinder has been retested under this section, unless that person holds a
current retester identification number issued by the Associate
Administrator for Hazardous Material Safety and operates in compliance
with the terms of the retester identification number issuance letter."

So, to finally answer your question of "how does an aircraft owner get
their oxygen system serviced legally?" I can offer this explanation. If
you have an installed oxygen system, all servicing must be done according
to the manufacturers instructions and/or AC 43.13-1B. 43.13-1B says that
the testing and marking of these cylinders must be done according to 49
CFR 173.34, which in turn specifies that the hydrstatic testing and
marking can only be done by someone who holds a current retester
identification number. So, the AMT would be obliged to take the cylinder
to someone who holds this retester identification number. This could be
an aviation-specific shop, or not. As long as they hold this
identification number and are operating under the terms of the issuance
letter for this number, then they can certify the tank. Your A&P would
then note this inspection in the aircraft logs, and everyone is happy.

On the other hand, if the oxygen system isn't an installed system, then
there is no legal requirement under the Federal Aviation Regulations
(anymore than there is a requirement for you to inspect a duffel bag or
any other item of cargo). However you still need to comply with 49 CFR
173.34 since the tank will be carried aboard an aircraft as cargo. In
this case, you should seek out someone who holds a retester identification
number as prescribed in 49 CFR 173.34 (e) (2) (i) and ask them to inspect
and certify your tank. Then, you're good to go.

I hope this is "legal-beagly" enough.

--Stefan


--
Stefan Murry

If the tank is "portable", and you will be having it hydro tested
locally, I suggest NOT using a welding supply place unless they test
on-site. If they throw a bunch of bottles in a truck to send off for
testing, your nice bottle will not come back looking the same.

bumper

On May 5, 10:06*am, bumper wrote:
If the tank is "portable", and you will be having it hydro tested
locally, I suggest NOT using a welding supply place unless they test
on-site. If they throw a bunch of bottles in a truck to send off for
testing, your nice bottle will not come back looking the same.

bumper

Yep, welding supply shops can be tricky.

Once I was on a errand to pick up a refilled (large type) O2 bottle.
While I waited for my turn at the counter, I noticed a truck being
unloaded at the dock. It was loaded with green O2 bottles - none of
which showed the blue "Aviation Oxygen" sticker.

Since I couldn't see any Aviation Oxygen bottles, I told the
counterman I wouldn't be surprised if he couldn't fill my order. "No
problem", he said, "Watch". He opened a drawer, retrieved a sheet of
blue Aviation Oxygen stickers and slapped one on the nearest green
bottle. "Now, he said, "I can sell you an Aviation Oxygen bottle -
that will be $115." "How much would it be without the sticker?"
"$35", he said.

It's surprising how honest people can be at times.

Wasn't it P.T. Barnum who said, "There's a sucker born every minute"?

ABO - Hah! I only had one year of chemistry in college, but I do recall
that an element is an element is an element. Oxygen is oxygen.


"Bill D" wrote in message
...
On May 5, 10:06 am, bumper wrote:
If the tank is "portable", and you will be having it hydro tested
locally, I suggest NOT using a welding supply place unless they test
on-site. If they throw a bunch of bottles in a truck to send off for
testing, your nice bottle will not come back looking the same.

bumper

Yep, welding supply shops can be tricky.

Once I was on a errand to pick up a refilled (large type) O2 bottle.
While I waited for my turn at the counter, I noticed a truck being
unloaded at the dock. It was loaded with green O2 bottles - none of
which showed the blue "Aviation Oxygen" sticker.

Since I couldn't see any Aviation Oxygen bottles, I told the
counterman I wouldn't be surprised if he couldn't fill my order. "No
problem", he said, "Watch". He opened a drawer, retrieved a sheet of
blue Aviation Oxygen stickers and slapped one on the nearest green
bottle. "Now, he said, "I can sell you an Aviation Oxygen bottle -
that will be $115." "How much would it be without the sticker?"
"$35", he said.

It's surprising how honest people can be at times.

On Monday, May 7, 2012 12:08:34 PM UTC-5, Dan Marotta wrote:
Wasn't it P.T. Barnum who said, "There's a sucker born every minute"?

ABO - Hah! I only had one year of chemistry in college, but I do recall
that an element is an element is an element. Oxygen is oxygen.


"Bill D" wrote in message
...
On May 5, 10:06 am, bumper wrote:
If the tank is "portable", and you will be having it hydro tested
locally, I suggest NOT using a welding supply place unless they test
on-site. If they throw a bunch of bottles in a truck to send off for
testing, your nice bottle will not come back looking the same.

bumper

Yep, welding supply shops can be tricky.

Once I was on a errand to pick up a refilled (large type) O2 bottle.
While I waited for my turn at the counter, I noticed a truck being
unloaded at the dock. It was loaded with green O2 bottles - none of
which showed the blue "Aviation Oxygen" sticker.

Since I couldn't see any Aviation Oxygen bottles, I told the
counterman I wouldn't be surprised if he couldn't fill my order. "No
problem", he said, "Watch". He opened a drawer, retrieved a sheet of
blue Aviation Oxygen stickers and slapped one on the nearest green
bottle. "Now, he said, "I can sell you an Aviation Oxygen bottle -
that will be $115." "How much would it be without the sticker?"
"$35", he said.

It's surprising how honest people can be at times.

.... Oxygen is oxygen.

I was just studying with my 2012 Private Pilot Test Prep book and found a relevant and hopefully interesting passage:

"Aviation oxygen should be used to replenish an aircraft oxygen systems... Oxygen used for medical purposes or welding normally should not be used because it may contain too much water. Specifications for Aviators' breathing oxygen are 99.5% pure oxygen and not more than .005 mg of water per liter of oxygen."

On May 7, 12:42*pm, wrote:
On Monday, May 7, 2012 12:08:34 PM UTC-5, Dan Marotta wrote:
Wasn't it P.T. Barnum who said, "There's a sucker born every minute"?

ABO - *Hah! *I only had one year of chemistry in college, but I do recall
that an element is an element is an element. *Oxygen is oxygen.

"Bill D" wrote in message
....
On May 5, 10:06 am, bumper wrote:
If the tank is "portable", and you will be having it hydro tested
locally, I suggest NOT using a welding supply place unless they test
on-site. If they throw a bunch of bottles in a truck to send off for
testing, your nice bottle will not come back looking the same.

bumper

Yep, welding supply shops can be tricky.

Once I was on a errand to pick up a refilled (large type) O2 bottle.
While I waited for my turn at the counter, I noticed a truck being
unloaded at the dock. It was loaded with green O2 bottles - none of
which showed the blue "Aviation Oxygen" sticker.

Since I couldn't see any Aviation Oxygen bottles, I told the
counterman I wouldn't be surprised if he couldn't fill my order. *"No
problem", he said, "Watch". *He opened a drawer, retrieved a sheet of
blue Aviation Oxygen stickers and slapped one on the nearest green
bottle. *"Now, he said, "I can sell you an Aviation Oxygen bottle -
that will be $115." *"How much would it be without the sticker?"
"$35", he said.

It's surprising how honest people can be at times.

... Oxygen is oxygen.

I was just studying with my 2012 Private Pilot Test Prep book and found a relevant and hopefully interesting passage:

"Aviation oxygen should be used to replenish an aircraft oxygen systems.... Oxygen used for medical purposes or welding normally should not be used because it may contain too much water. *Specifications for Aviators' breathing oxygen are 99.5% pure oxygen and not more than .005 mg of water per liter of oxygen."

That information was true 100 years ago but it's about a century out
of date. Oxygen today is made from a liquid air reduction process
which produces chemically pure oxygen. This is what is supplied to
all users. There's no incentive for the industry to deliberately
produce contaminated oxygen. There is zero water in any compressed
oxygen sold today.

If you dig a bit further, you'll find specifications for welding and
medical oxygen are far tighter than for 'aviation oxygen'.

On Monday, May 7, 2012 2:11:21 PM UTC-5, Bill D wrote:
On May 7, 12:42*pm, wrote:
On Monday, May 7, 2012 12:08:34 PM UTC-5, Dan Marotta wrote:
Wasn't it P.T. Barnum who said, "There's a sucker born every minute"?

ABO - *Hah! *I only had one year of chemistry in college, but I do recall
that an element is an element is an element. *Oxygen is oxygen.

"Bill D" wrote in message
....
On May 5, 10:06 am, bumper wrote:
If the tank is "portable", and you will be having it hydro tested
locally, I suggest NOT using a welding supply place unless they test
on-site. If they throw a bunch of bottles in a truck to send off for
testing, your nice bottle will not come back looking the same.

bumper

Yep, welding supply shops can be tricky.

Once I was on a errand to pick up a refilled (large type) O2 bottle.
While I waited for my turn at the counter, I noticed a truck being
unloaded at the dock. It was loaded with green O2 bottles - none of
which showed the blue "Aviation Oxygen" sticker.

Since I couldn't see any Aviation Oxygen bottles, I told the
counterman I wouldn't be surprised if he couldn't fill my order. *"No
problem", he said, "Watch". *He opened a drawer, retrieved a sheet of
blue Aviation Oxygen stickers and slapped one on the nearest green
bottle. *"Now, he said, "I can sell you an Aviation Oxygen bottle -
that will be $115." *"How much would it be without the sticker?"
"$35", he said.

It's surprising how honest people can be at times.

... Oxygen is oxygen.

I was just studying with my 2012 Private Pilot Test Prep book and found a relevant and hopefully interesting passage:

"Aviation oxygen should be used to replenish an aircraft oxygen systems.... Oxygen used for medical purposes or welding normally should not be used because it may contain too much water. *Specifications for Aviators' breathing oxygen are 99.5% pure oxygen and not more than .005 mg of water per liter of oxygen."

That information was true 100 years ago but it's about a century out
of date. Oxygen today is made from a liquid air reduction process
which produces chemically pure oxygen. This is what is supplied to
all users. There's no incentive for the industry to deliberately
produce contaminated oxygen. There is zero water in any compressed
oxygen sold today.

If you dig a bit further, you'll find specifications for welding and
medical oxygen are far tighter than for 'aviation oxygen'.

Well, I guess the source of at least some of the obviously widespread confusion is clear - our training materials are incorrect and/or just out of date and out of touch with technical reality. thanks.

Bill:

In addition to being pure, bottled oxygen made from liquid air is also super dry -- all traces of water are frozen out in the process. So the old problem with oxygen not being dry is no longer an issue.