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.

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