O2 cylinder

On 5 Feb 2006 14:18:32 -0800, "jcarlyle" wrote:

In the United States pressure vessels must be certified to either DOT
or ASME standards. If a pressure vessel to be used in the USA does not
have either DOT or ASME certification, it is illegal to use it, much
less to fill it.

John, can you provide support for that? I'm in the hydraulics
industry, and we have charged (and recharged) accumulators and gas
bottles for years that are neither DOT nor ASME approved. These are
not always old, nor small ... I worked with one gas bottle pressurized
to 3800 psi by N2 which cycles between 4200 and 4800 every 50 seconds
.... with a volume of over 200 gallons. I just commissioned a system
with 2 new (2005 manufacture) 32 liter accumulators that were bought
by others from others, but to which I pressurized. I "trusted" the
ratings stamped on the shell, but they had no approval stamps
(manufacturer offers ASME or TUV as options; neither engineer nor user
requested it). Am _I_ breaking the law?

We constantly wonder when pneumatic cylinders are going to be
considered pressure vessels in the USA; the PED (Pressure Equipment
Directive) of the EU already has criteria.

At 22:12 06 February 2006, Jphoenix wrote:

jcarlyle wrote:
George, I'm very surprised. All of the pressure vessels
I've ever
worked on over the last 30 years that were located
inside the USA have
had either DOT or ASME certification. I don't have
a reference for you
at the moment, but I've written a note about this
issue to a past
president of ASTM to get his input. I'll get back
to you with his
response.

Meanwhile, could you tell me exactly what the stamped
ratings on the
shell say that you are taking on trust?

-John


Fellas,

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sign off an annual on an aircraft with an out-of-date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

--
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

Hartley, On the question of "fitness for service" - a 15 year old
"good looking" cylinder could easily fail a hydrotest! The failure
probablility depends on factors such as (a) was it properly stress
relieved after it was made, (2) how often has it been cycled (filled,
refilled), (3) are there any inclusions in the metal, or any laps or
scratches on the interior, (3) are any small patches of corrosion
present on the inside, (4) were the neck threads cut properly. None of
these things will affect the cylinder's "looks" in any way, but they
will most certainly affect its ultimate life. The only way to find out
if there is stress corrosion cracking or fatigue cracking is to do a
hydrotest or an ultrasonic test (which is what I was doing for
customers).

As far as legalites go, the ex-ASTM president is still looking into the
question for me. However, I did a quick web search and turned up the
following relevant sites:

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/ed3ccb2b0c40bdad86256abf006f380c/$FILE/8000-40.pdf
This is FAA 8000.40D, "Maintenance of Pressure Vessels in Use as
Aircraft Equipment". Paragraph 6C is relevant one, and is as Gary Evans
stated above in his 2nd paragraph.

http://www.gawda.org/eSeries/Custome.../DOT/tab13.pdf
This is a summary of 49 CFR 173 that the Gases and Welding Distributors
Association offers to its members. Near the front, under Use and
Qualification of Cylinders, they say "49 CFR, §180 establishes the
requirements for the use and qualification of cylinders. A company may
not charge a cylinder that is out of test, leaks, has a bulge, has
defective valves or pressure relief devices, shows evidence of physical
abuse, fire or heat damage, or shows evidence of detrimental rusting or
corrosion."

Problem is, when I looked at 49 CFR 180 he
http://www.access.gpo.gov/nara/cfr/w...cfr180_99.html I
couldn't find anything that dealt with cylinders! If I could have, it
would have been the legal requirement we have been seeking!

Now, under Requirements for Filling and Shipping, they say 14 CFR
173.302 governs. That you can find he
http://frwebgate.access.gpo.gov/cgi-...99&TY PE=TEXT

I got totally lost in the formatting of this regulation, but near the
bottom, after the wall stress limitation table, the regulations says
"That an external and internal visual examination made at the time of
test or retest shows the cylinder to be free from excessive corrosion,
pitting, or dangerous defects.". This might also be part of a legal
requirement that you can't refill unless you test the cylinder, but to
me it seems an exercise in circular reference with 49 CFR 180

Maybe someone better versed in reading CFRs can give an opinion. To me,
it's as clear as mud!

-John



HL Falbaum wrote:

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?

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

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

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.

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

Eric Greenwell
Washington State
USA

www.motorglider.org

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.

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.