Another owner mx question

sferguson524

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Before i get flamed, or branded a troll...... I have done my research, read FAR 43, sacrificed a virgin to the FAA, and still am drawing a blank. Say i have a plane with a built in oxy bottle. Can I, as an owner, remove it, take it to my local gas passer and have it refilled, and reinstall and return the aircraft to service? Everything I find says no, but i will defer to the more knowledgeable here
 
The answer is no. You can not service a built in oxygen system as owner-pilot whether it involves removing the bottle or not.

Of course anybody can make the aircraft unairworthy. Take the bottle, have it filled, reinstall it and have a friendly mechanic approve the work.
 
Don't forget to check the date for pressure check.
 
Before i get flamed, or branded a troll...... I have done my research, read FAR 43, sacrificed a virgin to the FAA, and still am drawing a blank. Say i have a plane with a built in oxy bottle. Can I, as an owner, remove it, take it to my local gas passer and have it refilled, and reinstall and return the aircraft to service? Everything I find says no, but i will defer to the more knowledgeable here


Never seen an airplane without an external servicing port for built in oxygen, why would you want to gain access, pull the bottle, re-install bottle, and restore the airplane?
 
Good point, how would you get said bottle to the local welding supplier for filling otherwise?
 
Good point, how would you get said bottle to the local welding supplier for filling otherwise?
Build yourself a two or three tank cascade filler. Get a tank replenished when one runs low. It's perfectly legal to service your built in system, you just can't pull the installed tank out or put it back in without a mechanic's signoff.
 
that's exactly what i figured. But better safe than sorry to ask here
 
Build yourself a two or three tank cascade filler. Get a tank replenished when one runs low. It's perfectly legal to service your built in system, you just can't pull the installed tank out or put it back in without a mechanic's signoff.

Really? Justify that.
 
Really? Justify that.

Wouldn't filling the installed O2 system fall under "servicing" the aircraft similar to servicing the oil by adding a quart or servicing the fuel by pulling up to the self service pump and filling up? I can certainly argue that removing a O2 tank from an installed system listed on the equipment list (ie. Not a portable system) would have to be supervised and signed off by an Airframe mechanic.
 
Really? Justify that.
Justify which? (legal to service the built in system with O2 from a tank in your hangar or requirement for a mechanic's signature if you remove/reinstall the built in tank?)
 
I happen to have a memo to the Manager, Technical Programs Branch, AGL-230, from Aircraft Maintenance Division, AFS-300 requesting clarification on “Servicing of Aircraft Oxygen System” dated December 23, 2008 as follows:

Title 14 Code of Federal Regulations (14 CFR) does not define the term servicing when used in the context of aviation maintenance. The terms used by 14 CFR are maintenance and preventive maintenance. Based on the type of “service” to be completed, the job activity is classified as maintenance or preventive maintenance when using the definitions found in 14 CFR part 1.

· Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.

· Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance

Therefore, the “servicing of aircraft oxygen system is considered maintenance not preventive maintenance. Operators certificated under part 91 shall use mechanics or maintenances entities authorized under 14 CFR sections 43.3. Aircraft certificated under part 91 shall perform and document maintenance in accordance with 14 CFR part 91, subpart E.

There are no specific requirements in the CFRs for certification, manufacture, and maintenance of pressure cylinders used aboard aircraft. Title 14 CFR section 21.305, however, has a general provision that allows approval in any manner approved by the Administrator. Under this provision, pressure, cylinders have been approved by utilizing the requirements of the Department of Transportations, United States Coast Guard, Underwriters Laboratories, manufactures, and the military.
 
I happen to have a memo to the Manager, Technical Programs Branch, AGL-230, from Aircraft Maintenance Division, AFS-300 requesting clarification on “Servicing of Aircraft Oxygen System” dated December 23, 2008 as follows:

Title 14 Code of Federal Regulations (14 CFR) does not define the term servicing when used in the context of aviation maintenance. The terms used by 14 CFR are maintenance and preventive maintenance. Based on the type of “service” to be completed, the job activity is classified as maintenance or preventive maintenance when using the definitions found in 14 CFR part 1.

· Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.

· Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance

Therefore, the “servicing of aircraft oxygen system is considered maintenance not preventive maintenance. Operators certificated under part 91 shall use mechanics or maintenances entities authorized under 14 CFR sections 43.3. Aircraft certificated under part 91 shall perform and document maintenance in accordance with 14 CFR part 91, subpart E.
Total crap, and directly contrary to the black letter reading of the regulation. Adding oxygen to an installed O2 bottle is neither "inspection, overhaul, repair, preservation, [nor] the replacement of parts". It's no different than adding fuel to the tanks, oil to the engine, or air to the tires -- and you don't hear anyone in the FAA saying that's "maintenance" requiring a licensed mechanic even though they are not listed as "preventive maintenance" in Appendix A to Part 43. I'd love to see what the Chief Counsel would say about that memo.
 
"replacement of small standard parts"

I'd say O2 molecules are about as small and standard as you can get on an airplane
 
Total crap,

Your opinion.

and directly contrary to the black letter reading of the regulation.

Your opinion and carries absolutely no weight legally.

Adding oxygen to an installed O2 bottle is neither "inspection, overhaul, repair, preservation, [nor] the replacement of parts". It's no different than adding fuel to the tanks, oil to the engine, or air to the tires -- and you don't hear anyone in the FAA saying that's "maintenance" requiring a licensed mechanic even though they are not listed as "preventive maintenance" in Appendix A to Part 43.

And you have polled everyone in Flight Standards on this matter to make such a statement? :rolleyes:


I'd love to see what the Chief Counsel would say about that memo.

Your stock answer to everything. :rolleyes2:
 
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And you have polled everyone in Flight Standards on this matter to make such a statement? :rolleyes:
Enough that I'm not worried about making that statement. Or are you suggesting that you think there might be someone in Flight Standards who'd say adding fuel to the fuel tanks or oil to the engine is "maintenance" requiring at least the supervision and approval of someone with a mechanic certificate? I find it hard to believe that even you would say that just to argue with me.
 
Enough that I'm not worried about making that statement. Or are you suggesting that you think there might be someone in Flight Standards who'd say adding fuel to the fuel tanks or oil to the engine is "maintenance" requiring at least the supervision and approval of someone with a mechanic certificate?

I never made such a statement. I was questioning your absolute that "you don't hear anyone in the FAA saying that's "maintenance".

I simply don't believe you have the access nor the knowledge to make such a statement.

I find it hard to believe that even you would say that just to argue with me.

I didn't say that, you wrote it then implied I said it. You are simply doing that to avoid a direct question.
 
I never made such a statement. I was questioning your absolute that "you don't hear anyone in the FAA saying that's "maintenance".

I simply don't believe you have the access nor the knowledge to make such a statement.
Then don't believe it, and feel free to prove me wrong -- it will only take one FAA Inspector who says you need a mechanic certificate to fuel or add oil to your plane to do that. Good luck and good hunting. Until then, kindly bugger off.
 
Then don't believe it, and feel free to prove me wrong -- it will only take one FAA Inspector who says you need a mechanic certificate to fuel or add oil to your plane to do that. Good luck and good hunting. Until then, kindly bugger off.

Nice twist, but that's just your style.

Happy buggering! :rolleyes:
 
I have had installed O2 tanks filled at FBO's all over the country for 25 years and have NEVER had anyone offer or do a log book entry, which would be required if it was considered maintenance.

When the tank, regulator, plumbing or outlets are removed or inspected at annual that gets a log book entry as maintenance.

I pump my own gas, add my own oil, and fill my own O2 tanks.
 
FWIW, on a transport aircraft servicing the oxygen requires a maintenance sign off.

Yeah, and in the USAF so did fueling the aircraft. Not the same in GA/Part 91.
 
You do realize that aviators breathing oxygen is not interchangable with either industrial or medical oxygen, right?
 
You do realize that aviators breathing oxygen is not interchangable with either industrial or medical oxygen, right?

You do realize that its all one and the same and is absolutely interchangeable, right? I fill my airplane o2 at the same place i get my welding gas. In a pinch i fill from my own welding tank although i hate to get grief from my brother when we run out of gas.
 
You do realize that its all one and the same and is absolutely interchangeable, right? I fill my airplane o2 at the same place i get my welding gas. In a pinch i fill from my own welding tank although i hate to get grief from my brother when we run out of gas.

:yeahthat:

It all literally comes from the same very large tank of LOX. The difference is medical o2 cylinders are drawn down with a vacuum pump before filling. This comes from my grandfather who worked 25 years in the industrial gas business.
 
:yeahthat:

It all literally comes from the same very large tank of LOX. The difference is medical o2 cylinders are drawn down with a vacuum pump before filling. This comes from my grandfather who worked 25 years in the industrial gas business.

used to be true, not anymore.

All the exact same thing. Medical grade has a lot more paperwork and costs a lot more money, and requires a prescription in a lot of states.

I have used welding grade for scuba diving for 20+ years. I did a lot of research into O2 before I started. The tolerances for impurities in breathing gas are much lower with diving (high partial pressures) than flying (low partial pressures), and we have never had an issue.

I fill my own (portable) O2 system for my Cardinal off of the same welding bottles I use for my scuba diving.

-Dan
 
And actually if you look at the specs, welding grade had higher standards than breathing grade. A lot of the high end welding that is done requires purer gas than you need to breathe safely.

-Dan
 
used to be true, not anymore.

All the exact same thing. Medical grade has a lot more paperwork and costs a lot more money, and requires a prescription in a lot of states.

I have used welding grade for scuba diving for 20+ years. I did a lot of research into O2 before I started. The tolerances for impurities in breathing gas are much lower with diving (high partial pressures) than flying (low partial pressures), and we have never had an issue.

I fill my own (portable) O2 system for my Cardinal off of the same welding bottles I use for my scuba diving.

-Dan


You SCUBA with O2? Not around here.

Compressed air.
 
You SCUBA with O2? Not around here.

Compressed air.

Lots of folks in your neck of the woods used various mixed gasses for diving.

Some great deeper wrecks in the Great Lakes.

I use everything from 100% O2 (for deco, will kill you deeper than about 20ft), to mixes with only 6-8% Oxygen (300+ feet deep).

Air is a really crappy gas for diving. The Nitrogen is really hard on you. We used to not have a choice, but mixed gasses are much safer for diving.

I can teach someone how to safely dive with Nitrox (already a diver) in a couple hours.

-Dan
 
You SCUBA with O2? Not around here.

Compressed air.

Oops, somehow misread your location and was thinking Michigan, not Washington.

There are some really nice deeper dives in Washington state as well.

Plus with the cold water the extra safety factor of a higher Oxygen mix can be huge. Cold and Narcosis can really sneak up on you in colder water.

And even on shallower dives (60-80 foot range) the safety factor with some additional Oxygen over air is huge. We always thought it added a safety margin, but as our bubble models are getting better we are finding out it is even bigger than we ever thought.

-Dan
 
Dan,

Thanks! Strictly amateur here. No deep dives at all. But, I do have my card and on an off subscribe to DAN, mostly for their evacuation insurance.

K
 
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