Join ARSA Ask ARSA Pay ARSA

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

Helping FAA Quickly Meet New Foreign Oversight Requirements

On Oct. 4, ARSA joined Aircraft Electronics Association and Airlines for America in confirming for the FAA that new foreign oversight mandates from Congress’ reauthorization law are easily met through…Read More

Survey: Helping the Government’s Work

Researchers from the U.S. Government Accountability Office are auditing the FAA’s requirement that certificate holders waive the right to the Equal Access to Justice Act (EAJA) to obtain a settlement…Read More

U.S.-Brazil MIP Goes Live

On Oct. 1, the Maintenance Implementation Procedures (MIP) between the United States and Brazil entered into force. The FAA confirmed the agreement’s status in a Sept. 30 Information for Operators…Read More

FAA Acknowledges Repair Station Paperwork Burden

On Sept. 26, ARSA commented on the FAA’s second Federal Register notice regarding its assessment of the paperwork burden associated with FAA requirements for repair station certificate applications. In general,…Read More

Maintenance Educators Update Congress on Talent Pipeline

On Sept. 19, the Aviation Technician Education Council (ATEC) released its 2024 Pipeline Report. The report’s analysis was performed by Oliver Wyman Vector, which also produces ARSA’s Annual Market Assessment,…Read More
ARSA