ARSA RSS Feed ARSA LinkedIn
Contact Us Online 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

Going Back for More “Big Data”

The coffees are as small as the data is big…That’s going to be my ice breaking joke at @FlightGlobal‘s Aerospace Big Data Miami… https://t.co/XAPiSQ8w46 — Brett Levanto (@LevantoAir) August 21,…Read More

Dickson Sworn in as New FAA Administrator

Steve Dickson, former senior vice president of flight operations for Delta Air Lines, was sworn in as the FAA administrator by Transportation Secretary Elaine L. Chao on Aug. 12. Dickson…Read More

House Bill Would Address Contract Maintenance Transparency

On Aug. 8, Rep. Mark DeSaulnier (D-Calif.) introduced legislation that will potentially impact ARSA members and their airline customers. Generally, the Safe Landings Act (H.R. 4166) addresses the Air Canada…Read More

“100-percent Replacement” Makes 1-percent Progress

On Aug. 9, the FAA ended ARSA’s two-year wait for a response to its request to the Regulatory Consistency Communications Board (RCCB) for clarity regarding the right of repair stations…Read More

Hotline Highlight – Meet Me Halfway

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More
ARSA