O2 cylinder

[HL Falbaum]

Does anyone out there in r.a.s. land know how to get a German Oxygen
cylinder recertified to DOT specifications, and a place to get it done? I
think it is out of date, and I got I with the glider, a DG800B. It appears
to be in good shape-no dings or scratches. It has no DOT cert number on the
neck, and was imported with the glider-factory installed.

Thanks in advance
--
Hartley Falbaum

[chipsoars]

HL Falbaum wrote:
> Does anyone out there in r.a.s. land know how to get a German Oxygen
> cylinder recertified to DOT specifications, and a place to get it done? I
> think it is out of date, and I got I with the glider, a DG800B. It appears
> to be in good shape-no dings or scratches. It has no DOT cert number on the
> neck, and was imported with the glider-factory installed.
>
> Thanks in advance
> --
> Hartley Falbaum

Find a local place which does cylinder filling, most compressed gas
supply houses and diving equipment service houses can do hydrostatic
testing. e.g Airgas, Praxair, or BOC dealers. This should be done
every five years.

Google search turns up a lot of hits.

[bumper]

Do not hand your nice cylinder over to most welding supply houses. It'll
come back looking like it rode in a dump truck with 100 other loose
cylinders . . . probably 'cause it did!

Try a fire extinguisher servicing place.

bumper
"chipsoars" > wrote in message
oups.com...
>
> HL Falbaum wrote:
>> Does anyone out there in r.a.s. land know how to get a German Oxygen
>> cylinder recertified to DOT specifications, and a place to get it done? I
>> think it is out of date, and I got I with the glider, a DG800B. It
>> appears
>> to be in good shape-no dings or scratches. It has no DOT cert number on
>> the
>> neck, and was imported with the glider-factory installed.
>>
>> Thanks in advance
>> --
>> Hartley Falbaum
>
> Find a local place which does cylinder filling, most compressed gas
> supply houses and diving equipment service houses can do hydrostatic
> testing. e.g Airgas, Praxair, or BOC dealers. This should be done
> every five years.
>
> Google search turns up a lot of hits.
>

[Gary Evans]

I don't know what they put in fire extinguishers but
I can't imagine that its good to breath.


At 04:30 05 February 2006, Bumper wrote:
>Do not hand your nice cylinder over to most welding
>supply houses. It'll
>come back looking like it rode in a dump truck with
>100 other loose
>cylinders . . . probably 'cause it did!
>
>Try a fire extinguisher servicing place.
>
>bumper
>'chipsoars' wrote in message
oups.com...
>>
>> HL Falbaum wrote:
>>> Does anyone out there in r.a.s. land know how to get
>>>a German Oxygen
>>> cylinder recertified to DOT specifications, and a
>>>place to get it done? I
>>> think it is out of date, and I got I with the glider,
>>>a DG800B. It
>>> appears
>>> to be in good shape-no dings or scratches. It has
>>>no DOT cert number on
>>> the
>>> neck, and was imported with the glider-factory installed.
>>>
>>> Thanks in advance
>>> --
>>> Hartley Falbaum
>>
>> Find a local place which does cylinder filling, most
>>compressed gas
>> supply houses and diving equipment service houses
>> can do hydrostatic
>> testing. e.g Airgas, Praxair, or BOC dealers. This
>>should be done
>> every five years.
>>
>> Google search turns up a lot of hits.
>>
>
>
>

[GeorgeB]

On 5 Feb 2006 13:24:12 GMT, Gary Evans
> wrote:

>I don't know what they put in fire extinguishers but
>I can't imagine that its good to breath.

For the hydrotest, water. If the fire extinguisher places scare you,
try a scuba shop; they hydrotest theirs (by regulation on all
compressed gas cylinders of certain characteristics, I believe) every
5 years as well. Some do it in-house, some send them out.

I hedged there because I'm in the fluid power industry; we use
accumulators and "gas bottles" with nitrogen at pressures up to 6000
psi or so. SO FAR, I've never run into a recertification on European
or Japanese products. It may be DOT (where T is transportation);
stationary applications may be exempt.

I do run into requirements at purchase that they must meet the
appropriate country's criteria.

>At 04:30 05 February 2006, Bumper wrote:
>>Do not hand your nice cylinder over to most welding
>>supply houses. It'll
>>come back looking like it rode in a dump truck with
>>100 other loose
>>cylinders . . . probably 'cause it did!
>>
>>Try a fire extinguisher servicing place.

[[email protected]]

Hartley,
Sorry, but I don't think you can get it done. All the responses to
your question tell you where to get it hydo tested. That is not your
porblem. None of those places will test it - or they shoul not - as it
does not have a DOT certification. That is the problem with the
European bottles. Unless you find someone who does not follow the
rules ( and if you do you will probalbly have to take it back to them
each time as no one else will do it, they might put a phony DOT # on it
but if they will do that I would be worried about the quality of their
testing) or does not know the rules, which I have not found to happen
very often, you can not get it filled. If you have been getting it
filled so far you are lucky. If you have the small bottle you can
usually change to the US DOT "D" size. You may have to sand the
bottle sleeve just a bit. I have had this problem with two German
gliders.

Good luck

Tom
Idaho
HL Falbaum wrote:
> Does anyone out there in r.a.s. land know how to get a German Oxygen
> cylinder recertified to DOT specifications, and a place to get it done? I
> think it is out of date, and I got I with the glider, a DG800B. It appears
> to be in good shape-no dings or scratches. It has no DOT cert number on the
> neck, and was imported with the glider-factory installed.
>
> Thanks in advance
> --
> Hartley Falbaum

[Tim Mara]

you can not get a US DOT approval on German cylinders.they do not comply
with US DOT.....
tim
Wings & Wheels
www.wingsandwheels.com

"HL Falbaum" > wrote in message
...
> Does anyone out there in r.a.s. land know how to get a German Oxygen
> cylinder recertified to DOT specifications, and a place to get it done? I
> think it is out of date, and I got I with the glider, a DG800B. It appears
> to be in good shape-no dings or scratches. It has no DOT cert number on
> the neck, and was imported with the glider-factory installed.
>
> Thanks in advance
> --
> Hartley Falbaum
>

[HL Falbaum]

Well thanks guys----
Hope springs eternal, but it looks like the spring has run dry.
Title 49CFR Part 180 (Continuing Qualification)covers this and refers to
exemption letters for Foreign Cylinders. I have emailed DG to see if such an
exemption was ever made or documented--but I have my doubts.

Thanks for all your inputs

--
Hartley Falbaum
"Tim Mara" > wrote in message
...
> you can not get a US DOT approval on German cylinders.they do not comply
> with US DOT.....
> tim
> Wings & Wheels
> www.wingsandwheels.com
>
> "HL Falbaum" > wrote in message
> ...
>> Does anyone out there in r.a.s. land know how to get a German Oxygen
>> cylinder recertified to DOT specifications, and a place to get it done? I
>> think it is out of date, and I got I with the glider, a DG800B. It
>> appears to be in good shape-no dings or scratches. It has no DOT cert
>> number on the neck, and was imported with the glider-factory installed.
>>
>> Thanks in advance
>> --
>> Hartley Falbaum
>>
>
>

[jcarlyle]

In my professional capacity as a nondestructive test engineer, I was
peripherally involved in the successful effort to get DOT approval for
acoustic testing of high pressure cylinders carrying gasses on truck
trailers, as well as for acoustically testing composite liquefied
natural gas cylinders used in automobiles. I have also personally used
acoustics to inspect pressure systems used in Mach 14 wind tunnels that
involve pressures up to 60,000 (yes, sixty thousand) psi of air. Those
were some crazy thick walled pressure vessels...made the 16 inch rifles
on the battleship New Jersey look puny!

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. For example, check out Michelin, Continental,
Bridgestone, Dunlop or Pirelli tires - they all have a DOT approval for
USA usage, even though they aren't made here. Yes, tires are considered
to be a pressure vessel - so is your hot water heater, for that
matter.

Sorry, Hartley, you're going to have to buy another oxygen cylinder
if you want to be legal.

-John

[Shawn]

jcarlyle wrote:
> In my professional capacity as a nondestructive test engineer, I was
> peripherally involved in the successful effort to get DOT approval for
> acoustic testing of high pressure cylinders carrying gasses on truck
> trailers, as well as for acoustically testing composite liquefied
> natural gas cylinders used in automobiles. I have also personally used
> acoustics to inspect pressure systems used in Mach 14 wind tunnels that
> involve pressures up to 60,000 (yes, sixty thousand) psi of air. Those
> were some crazy thick walled pressure vessels...made the 16 inch rifles
> on the battleship New Jersey look puny!
>
> 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. For example, check out Michelin, Continental,
> Bridgestone, Dunlop or Pirelli tires - they all have a DOT approval for
> USA usage, even though they aren't made here. Yes, tires are considered
> to be a pressure vessel - so is your hot water heater, for that
> matter.

Bicycle tires and rims too (never heard this)? *Much* higher pressure
than car tires.

Shawn

[GeorgeB]

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.

[jphoenix]

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/examiners_inspectors/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, § 180.205, formerly part 173, §
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

[Gary Evans]

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/examiners_inspectors/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?

[GeorgeB]

On 6 Feb 2006 07:35:13 -0800, "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?

Ishould have prefaced my comments with "I work in INDUSTRIAL AND
MOBILE FLUID POWER, not aerospace", so our situations may be very
different. Other than the QA requirements, a hydrotest is a
hydrotest, and I'm not sure that breathing oxygen cylinders for use in
a plane have any different requirements than on the ground ... but I
DON'T KNOW THAT. I have performed a hydrotest on SCUBA cylinders; we
didn't use certified gauges or anything; our criteria was recovery
from 5/3 "rating" confirming plastic deformation was not reached.

They will always have a maximum working pressure stamped in either PSI
or bar. They will often have a minimum termperature.

I did a little digging and find that most today for US use design to
Section VIII Div 1 and either stamp (U) all or upon premium payment
(which I suspect is an indicator of QA costs).

I found that those with IDs of less than 6" do not fall under ASME
criteria. That appears insignificant as the "standard" for common
bladder accumulators is 9" OD; I'm sure the shells are under 1/2 inch.

A quick look at Tobul, Vickers, and Hydac suggest they routinely stamp
theirs. Parker has an extra charge for it.

What I have _NEVER_ seen is one subjected to hydrotest.

MOST of what I run into are between 1 and 15 gallon, either 2000,
3000, or 5000 psi "rated", and of diaphram, bladder, or piston
construction. ALL use N2 as the specified gas. I've had customers
use Argon against my recommendation.

Have a good week,

George

[HL Falbaum]

--
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/examiners_inspectors/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

[Gary Evans]

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/examiners_inspectors/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.

[Eric Greenwell]

Gary Evans wrote:

>>
>>Here's the current FAA guidance on the subject: (HBAW
>>02-01B)
>>http://www.faa.gov/library/manuals/examiners_inspectors/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

[Tim Mara]

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

[jcarlyle]

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/Customer/Source/gawda_members/Resources/newsletters/CM/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 here:
http://www.access.gpo.gov/nara/cfr/waisidx_99/49cfr180_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 here:
http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi?TITLE=49&PART=173&SECTION=302&YEAR=1999&TYPE=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]

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/examiners_inspectors/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.

[jphoenix]

I think you got it right Gary. Those 180 and 173 rules are all about
transportation in commerce. However, most IA's will still want to see a
hydro date if that bottle is in your glider during your annual.

Jim

[jcarlyle]

Jim, Gary - did you guys read the following (FAA Order 8000.40D)?
http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/ed3ccb2b0c40bdad86256abf006f380c/$FILE/8000-40.pdf

1. It applies to Part 91 aircraft, among others (para 1)
2. It says the FAA Adminstrator has adopted "the rules and regulations
of DOT, RSPA, USCG, UL, MIL-SPEC, and applicable manufacturers as
acceptable methods for controlling the hydrostatic tests and life
limits of pressure cylinders" (para 4d)
3. It says "pressure cylinders used aboard aircraft should be
maintained under the same specifications prescribed by the appropriate
regulatory agency and manufacturers if no other requirements are
available." (para 4e)
4. It says "Cylinders which have reached their hydrostatic test due
date cannot be recharged or installed until hydrostatically tested."
(para 6e)

This seems pretty clear - even if your oxygen tank is non-DOT approved,
you have to follow the manufacturer's specs and you have to have it
hydrostatically tested in order to use it in your aircraft.

-John

jphoenix wrote:
> I think you got it right Gary. Those 180 and 173 rules are all about
> transportation in commerce. However, most IA's will still want to see a
> hydro date if that bottle is in your glider during your annual.
>
> Jim

[jphoenix]

John,

That Order was cancelled. It is replaced by HBAW 02-01B.

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/ED3CCB2B0C40BDAD86256ABF006F380C?OpenDocument&Highlight=8000.40d

Jim

[Gary Evans]

At 17:18 08 February 2006, Jcarlyle wrote:
>Jim, Gary - did you guys read the following (FAA Order
>8000.40D)?
>http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders
>>.nsf/0/ed3ccb2b0c40bdad86256abf006f380c/$FILE/8000-40.pdf
>
>1. It applies to Part 91 aircraft, among others (para
>1)
>2. It says the FAA Adminstrator has adopted 'the rules
>and regulations
>of DOT, RSPA, USCG, UL, MIL-SPEC, and applicable manufacturers
>as
>acceptable methods for controlling the hydrostatic
>tests and life
>limits of pressure cylinders' (para 4d)
>3. It says 'pressure cylinders used aboard aircraft
>should be
>maintained under the same specifications prescribed
>by the appropriate
>regulatory agency and manufacturers if no other requirements
>are
>available.' (para 4e)
>4. It says 'Cylinders which have reached their hydrostatic
>test due
>date cannot be recharged or installed until hydrostatically
>tested.'
>(para 6e)
>
>This seems pretty clear - even if your oxygen tank
>is non-DOT approved,
>you have to follow the manufacturer's specs and you
>have to have it
>hydrostatically tested in order to use it in your aircraft.
>
>-John
>
>jphoenix wrote:
>> I think you got it right Gary. Those 180 and 173 rules
>>are all about
>> transportation in commerce. However, most IA's will
>>still want to see a
>> hydro date if that bottle is in your glider during
>>your annual.
>>
>> Jim
>
>

Yes, that was covered several posts back. FAA wants
the cylinder tested as if it were DOT approved which
is very reasonable. Getting a hydro on a non-DOT 02
cylinder is no problem.

[Graeme Cant]

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

[jcarlyle]

Jim, well that's a bummer! Someone writes an order to bring clarity to
a murky area, then that order is made obsolete by a superceding
directive which leaves us in the dark again. Perhaps this is why my
ASTM buddy hasn't been able to find anything to answer George's
question. It may be that use of pressure systems is not driven by
regulation so much as common sense, fear of litigation, and the
influence of insurance companies.

To answer JW's questions, aluminum and steel are pretty equal with
regard to safety. Of course, aluminum is generally more susceptible to
stress corrosion cracking than steel, and it will have a lower fatigue
life, so I would chose steel if you can stand the weight. The metal
alloys chosen for this application are ductile, so in neither case
would shrapnel be likely to be an issue. (The exception might be if the
bottle were cold enough at altitude to be below its ductile to brittle
transition temperature.) But, exploding in flight would be a pretty
unlikely event; refilling is the dangerous process as it puts rising
tension on any crack tip that may exist.

That said, you really don't want to be anywhere near a failing high
pressure cylinder! There will be an extremely high speed, high pressure
jet going in one direction, and a metal bottle going in the opposite
direction. Failing bottles have been known to go through solid concrete
walls, while high pressure jets have been known to cut people apart.

No one has remarked on the engineering behind these bottles. There are
three main concerns, flaws, fatigue life and corrosion. Flaws are
mostly found through hydrotesting; if a bottle passes it means any flaw
is below the critical crack size for the material. The crack growth
rate per fatigue cycle figure is determined for the material, and the
retest interval is chosen such that a sub-critical crack cannot grow
through refill cycling to critical crack size during the interval. But
fatigue cracking isn't the only mechanism of failure, stress corrosion
crack growth can occur simply by the passage of time, without any need
for stress cycles (it can happen to a full cylinder sitting on the
shelf).

A careful and prudent individual will get his high pressure cylinder
hydrotested every five years (or whatever the manufacturer recommends).
Remember, it's not just the number of refills, it's time passing itself
that can get you. If you think hyrotesting is expensive or
inconvenient, then I recommend you keep in mind Dirty Harry's question
"do you feel lucky?"

-John

jphoenix wrote:
> John,
>
> That Order was cancelled. It is replaced by HBAW 02-01B.
>
> http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/ED3CCB2B0C40BDAD86256ABF006F380C?OpenDocument&Highlight=8000.40d
>
> Jim

[Eric Greenwell]

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