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#11
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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. |
#12
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O2 cylinder
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...300/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 Most IA's will not sign off an annual on an aircraft with an out-of-date hydro.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 |
#13
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O2 cylinder
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? |
#14
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O2 cylinder
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 |
#15
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O2 cylinder
-- 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 |
#16
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O2 cylinder
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. |
#17
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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. -- Change "netto" to "net" to email me directly Eric Greenwell Washington State USA www.motorglider.org |
#18
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O2 cylinder
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 |
#19
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O2 cylinder
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? |
#20
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O2 cylinder
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. |
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