ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

Maintaining High-Pressure Cylinders Under Titles 14 and 49 CFR

On January 28, 2011, ARSA submitted a letter to the FAA requesting changes to existing and recently released guidance regarding the maintenance requirements for high-pressure cylinders. The letter addressed FAA rationale that the Pipeline and Hazardous Materials Safety Administration (PHMSA) has sole jurisdiction over maintaining the cylinders and, therefore, the FAA cannot issue a repair station rating for that work. ARSA pointed out that such maintenance is not performed solely under PHMSA rules (49 CFR). Instead, a cylinder removed from an aircraft must be maintained in accordance with all pertinent requirements, which includes 14 CFR part 43; therefore, a repair station authorized by PHMSA technically violates 14 CFR parts 43 and 145 when it performs maintenance on a cylinder destined for installation on an aircraft with a U.S. airworthiness certificate. Persons performing maintenance, preventive maintenance and alterations on articles installed on type certificated aircraft with a U.S. airworthiness certificate must have appropriate authority (14 CFR § 43.3); a repair station is authorized to perform maintenance, preventive maintenance and alterations (14 CFR § 43.3(e)), but it cannot operate in violation of its certificate, rating or operations specifications (14 CFR § 145.5).

ARSA asked the FAA to simply issue limited specialized service ratings to repair stations approved by PHMSA to perform maintenance on pressure cylinders; that way, the FAA will recognize the repair station’s PHMSA qualifications (that it has the housing, facilities, equipment, data and personnel) to perform the work and simply transfer that approval into a rating. ARSA’s letter to the FAA is available here.

ARSA’s 2008 letter on the issue may be found here.



More from ARSA

ARSA Leads Industry Effort for “Serious” Standardization

On May 23, a coalition of aviation industry associations and private businesses sent a letter to the FAA seeking an objective standard for service difficulty reports under § 145.221. The…Read More

Online Training – Full ICA Series Available On Demand

View ARSA’s three-part series on instructions for continued airworthiness (ICA), led by Managing Director and General Counsel Marshall S. Filler. ICA has been a key focus of ARSA’s work on behalf…Read More

ARSA’s Filler at EASA STeB: Rulemaking, Personnel Moves and “Hard Law”

On May 9, Marshall S. Filler, ARSA’s managing director & general counsel attended the EASA Engineering & Maintenance Stakeholder Technical Body (E&M STeB) in Cologne, Germany. The meeting was chaired…Read More

AMT Day 2017 – No Days Off

Charles Taylor Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 149 years later – we celebrate him with every…Read More

ARSA, A4A Collaborate on Regulatory Reform Suggestions

On May 19, ARSA joined Airlines for America (A4A) in submitting to the Aviation Rulemaking Advisory Committee (ARAC) a list of rules the associations would like to see repealed, modified…Read More
ARSA