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Dedicated to the advancement of the international helicopter community

www.rotor.com

November 13, 2012

U.S. Department of Transportation

Docket Operations, M-30

West Building ground floor

Room W12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

Re: Petition for Extension of Exemption: Exemption No. 6002H, FAA Docket No. 2002-

12804

Dear Sir or Madam:

On December 16, 1994, the Federal Aviation Administration (FAA) granted Exemption No. 

6002 to Helicopter Association International (HAI) and the Association of Air Medical 

Services (AAMS) (hereinafter, the “Petitioners”). This exemption, from § 43.3(a) of the 

Federal Aviation Regulations (FAR), was granted “to the extent necessary to allow pilots 

employed by member operators of the petitioners, not permitted under § 43.3(g) to perform 

preventative maintenance, to remove and reinstall LOX [Liquid Oxygen System] containers in 

their aircraft, after receiving and documenting appropriate training in this task by a properly 

certificated airframe mechanic,” subject to certain conditions and limitations stated therein. 

Since the first Exemption No. 6002 was granted, it has been extended every two years. The 

latest extension, Exemption No. 6002H will expire, by its own terms, on January 31, 2013.

The conditions and circumstances pursuant to which Exemption No. 6002 was originally 

granted remain unchanged. Experience with Exemption No. 6002 demonstrates that the public 

interest is served and a level of safety equivalent to regulation is maintained when properly

trained air medical service pilots are permitted to remove and reinstall LOX containers in their 

aircraft. Pursuant to FAR §11.87, good cause exists to waive publication of this petition for 

extension of exemption in the Federal Register, because the extension, if granted, would not set 

a precedent, and any delay in acting on this petition would be a detriment to the Petitioners and 

the public.

Exemption No. 6002 remains vital to the public interest despite the addition to the federal 

aviation regulations of subsection 14 CFR § 43.3(i), which authorizes properly trained pilots of 
Dedicated to the advancement of the international helicopter community.

certain aircraft operated pursuant to 14 CFR part 135 to remove and reinstall “approved cabinmounted medical oxygen bottles” only “when no tools are required.” Exemption 6002 

authorizes trained air medical aircraft pilots “to remove and reinstall LOX containers in their 

aircraft” using simple hand tools when “no special tools are required to perform the container 

exchange,” subject to the conditions stated therein. 

Therefore, HAI and AAMS petition the Administrator to extend Exemption No. 6002 for an 

additional two-year term, or for such longer term as the Administrator may deem appropriate. 

The Petitioners further ask the Administrator to find good cause exists to waive publication. 

Sincerely,

Matthew S. Zuccaro

President

cc: Mr. Rick Sherlock, CEO, AAMS