# Presentation: 137441

## Hydrostatic Test Interval of Fire Extinguishers

- STANDARDIZATION OF HYDROSTATIC TEST INTERVALS FOR FIRE EXTINGUISHERS

**Notes:**
The IHRWG is discussing since approximately 2 years that the Hydro Test Intervals for Fire Extinguishers should be changed from  5 years to a longer period, to reduce the lost of Halon.
The Working Group "Hydrostatic Exemptions" was established by the IHRWG on April 1997 in Long Beach.
Members: Donald Bein	UTRS/ U.S.NNAVY	FAX: (609) 667 7586
Dan. Carl	UTRS/ U.S.NNAVY	 FAX: (609) 667 7586
Hilde Schellingeehout  	KLM	FAX: 0031 20-648-8162
Marco Potschkat	Airbus Industries	FAX: 0033 5-61-93 4908
Garry Padvaiskas	Air Canada	FAX: (514) 422 4909
Felix Stössel	Swissair	 FAX: 0041 1-812-9098
Jim Thomson	CASP Aerospace	 FAX: (514)630 9999
Larry Cromwell	United Airlines	 FAX: (650)634 4798
Bill Leach	U.S. Navy	 FAX: (732) 323-7219
Richard Lamontage	Mitre	 FAX: (781) 271-6143
Hans Humfeldt	Lufthansa Technik	 FAX: 0049- 04109-250733
		E-mail: Hans.Humfeldt@t-online.de
Members since 12.March 2002 (Seattle Meeting):
Sham Hariram	Boeing Com. A/C 	Phone:  (562) 982 0899
	 Long Beach Div.        	  E-mail: sham.s.hariram@boeing.com
Conrad Roseburg	Boeing Seattle Bcag                	  Phone: (425) 234 5201
  	                                      	E-Mail: Conrad.m.roseburg@boeing.com
Virinder Duggal	Goodrich, Lynnwood W.A.	Phone: (425) 825 8615
                                                                                        E-mail: VIRINDER.DUGGAL@AEROSPACE.BFG.com

## Hydrostatic Test Interval of Fire Extinguishers

**Goal**** **
-     Fourteen years Hydrostatic Test Interval                  for Fire Extinguishers                    should be allowed                      **for all users.**

**Notes:**
In 1994 the DOT issued the DOT-E 10990 Exemption which
allows ATA members to extend the Hydro. Test Interval from 5  to 14 years.
Non -ATA Members have to test at 5 years interval in accordance with
 49 CFR § 1732.34 (e).

The IHRWG must officially request that DOT -E 10990 be revised to permit all (ATA and non- ATA) members to extend the hydrostatic test from 5 to 14 years. 
This request (with endorsement of US EPA) must be submitted by the Chairman, IHRWG, on behalf of the group.
The Chairman must report to IHRWG at the next meeting.

## Hydrostatic Test Interval of Fire Extinguishers

**Request**** **
- 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.

**Notes:**

1.	It should be the goal for every body, to reduce the amount of Halon, released into the atmosphere.
2. Most of the leaks are results from a repair / welding
2.	Hydrostatic test requires:

	-	Emptying of halon bottle
	-	Recycling the Halon by separating it from CO2  and 	contaminants.
	-	Recharging of bottle with Halon.Approximately 5% Halon is released to the atmosphere during this process.

## Hydrostatic Test Interval of Fire Extinguishers

**Background**
- 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

## Hydrostatic Test Interval of Fire Extinguishers

**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.

**Notes:**
Thanks to: 
	Alan Gupta 		BC
	Thomas Grabow	DASA
	Carol Hipsher	MDC
for the assistance getting all the data.

## Hydrostatic Test Interval of Fire Extinguishers

**Quantity of Halon in the Commercial Aircraft fleet**

**Notes:**

Not included in the  database is the amount of Halon
	-  used in Aircraft built by other manufacturers
	   than BC, DASA MDC
	- smaller Aircraft where the Cargo Compartment	  was modified from class “C” to class “D” 
	- Military Aircraft
	- Halon used in Portable Extinguishers and Potty 		  Bottles

## Hydrostatic Test Interval of Fire Extinguishers

**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 $

**Notes:**
Calculation:
25,4 tons in 5 years       (25,4   / 5   *14) = 71,1 tons in 14 years

The lost of 5%  is based on a study of the fleet of approximately 450 Airplanes, flown by 

	- Lufthansa
	- Lufthansa subsidiaries
	-  approximately  80 "Total Technical Support" 	   Customers
	-  regular customers .

## Hydrostatic Test Interval of Fire Extinguishers

**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 $

**Notes:**
This calculation does not take into consideration that some Fire Extinguishers will be used for 
- fire fighting 
- at false alarms. 	  (acc. to LHT statistic 74 ea  of 383 ea,-19%)
Those Fire Ext. will be overhauled (hydrostatic tested and charged) earlier than in 14 years.

That means the saving of Halon is smaller than 44,6 tons,
but we also have to take into consideration, that at this Extinguishers the work steps "discharging" and "recycling" have not to be made. The result is, that the amount of lost Halon is smaller than 5%.
Conclusion: We can use the 44,6 ton as an estimate.

## Hydrostatic Test Interval of Fire Extinguishers

**Present 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

**Notes:**
Parameters for checks and  tests have to be the same for all operators.We don't have control over regulations, issued by authorities of the different countries, but one authority should not request different parameters from different operators.

## Hydrostatic Test Interval of Fire Extinguishers

**Actions 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

**Notes:**
FAA and EPA where asked for  assistance, but without a reaction 
Reactivation of  the FAA-Order 8000.40 aThe FAA Order 8000.40(a) was issued 17. July 1983In Item 7. it was said:Application of CFR49, Section 173.301 (c), Retest of Container, states:"A container for which prescribed periodic retest has become due must not be charged and shipped until such retest has been properly made." Therefore, pressure cylinders used as aircraft equipment which remain charged on the due date of its hydrostatic test may remain in service beyond the test date providing that the cylinder is retested prior to its next full or partial refilling.We in Lufthansa have had very good experience with the FAA-Order 8000.40a, but it was cancelled 18. Oct. 1990.Sure, the 8000.40a should not again made been valid for Pressure Vessels generally, but for Fixed Fire Extinguishers it would be ok. 

## Hydrostatic Test Interval of Fire Extinguishers

**Actions 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

**Notes:**
Because of no reaction of the US- Authorities some European Airlines have asked the AEA for assistance, which was accepted by the AEA.

The AEA has 29 Airlines as Members. All Airlines are offering scheduled routes.Charter Airlines are not members 
If we could have get the wording of the DOT-E 10990 changed to give the AEA Members the allowance to perform Hydrostatic Testing after 14 years, Charter Airlines  would not benefit as all other non ATA AEA Members would not benefit.

## Hydrostatic Test Interval of Fire Extinguishers

**Actions 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

**Notes:**
We have made several approaches to get a permit from the DOT to get the same benefits as they are given to the ATA Members.

We have offered to the DOT to make also special annual reporting as it was made by the ATA

but with all our efforts we did not get any success!

## Hydrostatic Test Interval of Fire Extinguishers

**Future**
**What shall we do next**
**to reach our purpose?**