hans humfeldt, lufthansa technik ag, meeting in seattle (12./13. march 2002) 1 hydrostatic test...

Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 1

Hydrostatic Test Interval of Fire Extinguishers

STANDARDIZATION OF HYDROSTATIC TEST

INTERVALS FOR FIRE EXTINGUISHERS



GoalGoal

Fourteen years Hydrostatic Test Interval for Fire Extinguishers should be allowed

for all users.



RequestRequest

Hydrostatic Test of Halon bottle should be performed not more than necessary

The frequency should be based on maintenance data.

Hydrostatic Test Requirements for Fire Extinguishers must be the same for all users.



BackgroundBackground The working Group was established in

April 1997 1999 it was discussed to close the

Working Group because of no progress but the members of the IHRWG Meeting decided to continue



Facts of the past situation Facts of the past situation (1997 - 2002)

The following matrix gives an overview of the Quantity of Halon in the fleet

(commercial Aircraft : Airbus, Boeing and MDC)as of December 31. 1997 The quantities are round figures.Not included in the calculation are Class “C” to Class “D” modifications.



Engine APU CargocompartmentAC Type Number of Number of Weight / AC Halon in total Number of Weight / AC Halon in total Number of Weight / ACHalon in total

Airplanes Bottles/ AC ( lbs) fleet (to) Bottles/ AC (lbs) fleet (to) Bottles/ AC (lbs) fleet (to)

A300 442 4 84,0 16,9 1 5,0 1,0 1 resp. 2 122,0 24,5A310 252 4 84,0 9,6 1 5,0 0,6 2 135,5 15,5A319 65 4 44,5 1,3 1 5,0 0,1 0 resp.1 18,7 00,6A320 605 4 44,5 12,2 1 5,0 1,4 1 resp.2 18,7 05,1A321 76 4 44,5 1,5 1 5,0 0,2 1 resp.2 00,0A330/340 190 4 resp. 8 80,0 6,9 1 5,0 0,4 2,0 150,7 13,0

1630 48,4 3,7 58,7

B707 284 4 18,0 2,3 -- -- -- -- -- -- B727 1514 2 20,0 13,7 1 2,0 1,4 -- -- -- B737 3832 2 13,0 22,6 1 1,1 1,9 -- -- -- B747 1070 4 resp. 8 47,8 23,2 1 18,0 8,7 2 resp. 4 209,9 102,0B757 790 2 27,6 9,9 1 8,5 3,0 2 45,0 16,1B767 692 2 resp. 4 25,9 8,1 1 12,6 4,0 2 resp.3 155,0 48,7B777 137 2 44,0 2,7 1 14,0 0,9 5 321,0 20,0

8319 82,7 19,9 186,8

MD11 DC10 613 6 96,0 26,7 1 16,0 4,5 2 resp.6 168,6 46,9DC8 294 4 50,4 06,7 0 0,0 0,0 0,0 0,0 00,0MD80/DC9 1998 2 23,9 21,7 0 0,0 0,0 0,0 0,0 00,0MD90 93 2 29,0 01,2 1 4,5 0,2 0,0 0,0 00,0

2998 56,3 4,6 46,9

Total 22 896 187,5 28,3 292,4

Total amount of Halon in world wide fleet (tons): 508,1 Data based of the fleet 1997

Quantity of Halon in the Commercial Aircraft fleet



Facts of the past situation Facts of the past situation (1997)

There was 508 tons of Halon in the fleet of Airbus and Boeing (including Douglas Product Division).

5% of Halon is lost at each overhaul (25,4 tons at each overhaul period).

If the Hydro Test is performed every 5 years, 5 tons of Halon are released annually to the atmosphere. (= 70 tons within 14 years)

Valued (5000 X 30 $) = 150 000 $



Facts of the past situation Facts of the past situation (1997 - 2002)

If the DOT-E 10990 is changed to allow 14 year interval only

25,4 tons in stead of 71,1 tons will be released to the atmosphere.

This will prevent release to the atmosphere of 45,7 tons.Valued (45700 X 30 $) = 1 371 000 $


Hydrostatic Test Interval of Fire Extinguishers Present situation of Hydrostatic Test IntervalPresent situation of Hydrostatic Test Interval

The DOT requires in general an interval of 5 years. The Fire Extinguisher Manufacturers W. Kidde and

Pacific Scientific recommend 14 years interval. The DOT -E 10990 has allowed an interval of 14 years,

but only to ATA Members. This DOT Exemption has expired 31.Jan. 2002 and was not prolonged.There are rumours telling, that it remains cancelled for ever.

There was a Draft of an FAA Order 8000.40 issue “E” at the FAA WEB, but it is deleted


Hydrostatic Test Interval of Fire Extinguishers Actions taken since 1997Actions taken since 1997

IHRWG under the stewardship of Chairman and co-operation of EPA was asked to request DOT to amend the rule.

There are 3 possibilities:– reactivating of FAA-Order 8000.40 a– eliminating the Hydro Test for Fire Extinguishers– changing the wording of the DOT-E 10990

to allow the 14 years interval for all operators– accept the interval, suggested by the manufacturers



Actions taken since 1997Actions taken since 1997

The European Airlines under stewardship of the AEA (Association of European Airlines) have made 4 request to the DOT

All requests have been refused


Hydrostatic Test Interval of Fire Extinguishers Actions of AEAActions of AEA

– Request for an Exemption under 49 CFR Subpart B (23.Jun. 2000)

Refused because of no jurisdiction over periodic maintenance / inspection programs of non-US Flag airlines

– Same request as above but for FAA Certified European Airlines only Letter was lost. No answer.

– Same request as above Refused because of same reason as above:

No jurisdiction and rewriting of the DOT-E10990

– Request to get a waiver from FAA-Order 8000.40 D .(Was suggested by the RSPA, USDOT)

Refused. Suggestion: Ask your local Authorities for a release


Hydrostatic Test Interval of Fire Extinguishers FutureFuture

What shall we do next to reach our purpose?

hans humfeldt, lufthansa technik ag, meeting in seattle (12./13. march 2002) 1 hydrostatic test...

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