Date: 201506
Location: ZZZ.Airport, US
Aircraft: EC135
Operator: Air Taxi
Operating under: Part 135
Mission: Passenger
Reporter organization: Air Taxi
Reporter function: Captain; Pilot Flying
Reporter qualification: Flight Crew Air Transport Pilot (ATP)
Human factors: Training / Qualification
Anomaly: Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Hazardous Material Violation
Detector: Person Flight Crew
When detected: In-flight
Result: General None Reported / Taken
Contributing factors: Company Policy; Equipment / Tooling; Human Factors
Primary problem: Human Factors

Narrative: Recently; I was on a flight carrying a specialty team from one hospital to another.  It was learned on the return leg that the team recently outfitted their program's wearable life vests with HEEDS devices that their 'program' apparently recently procured.  I had mentioned in the past that these HEEDs devices were 2.2 HAZMAT materials; in that they are 3000 psi compressed gas bottles and that we do not carry a HAZMAT certificate.  Apparently; these devices have become part of the team's standard 'flight' uniform now; and since they are 'customers'; I should consider this as part of their carry-on equipment.  To me; whether considered aircrew; passengers; customers; or even patients; the HEEDS bottle should be considered 2.2 HAZMAT if carried on any company aircraft; especially on aircraft operating under PART 135.GOM Chapter 8 Hazardous Materials:8.1 [Company] will not accept and/or knowingly transport hazardous materials as defined by 49 CFR onboard our aircraft. 8.3 Any package or cargo that displays a hazardous materials marking label or is otherwise known or suspected to contain a hazardous material; will not be accepted or loaded aboard [Company] aircraftDivision 2.2 (Non-flammable; non-poisonous compressed gas-including compressed gas; pressurized cryogenic gas and compressed gas in solution) means any material or (mixture) which exerts in the packaging absolute pressure of 280 kPa (41 psi) or greater at 20C (68F) and does not meet the definition of Division 2.1 or 2.3.Lifesaving Systems; Inc; manufacturer of HEEDS devices; indicates that all their HEEDS devices are 3000 psi pressurized containers.  (ref:http://www.lifesavingsystems.com/base/product_pages/egress1_1.htm)According to the referenced literature; the HEEDS bottles are class 2.2 hazardous materials because they are 3000 psi compressed gas aluminum cylinders where the Hazardous Material regulation tells us that such cylinders are limited to 41 psi. Also; these devises are NOT medical in nature; therefore; do not qualify for the FAA blanket exemption for medical O2.[Company] policy is clear that it WILL NOT CARRY any hazardous materials; which the HEEDS bottles clearly seem to be.  Lifesaving Systems develops and sells products to many military customers.  The military carrying of HEEDS bottles is not governed by the FAA regulations.  The Lifesaving Systems HEEDS are not FAA TSO'ed or STC'ed.; and the HEEDS bottles are not on Air Methods approved maintenance tracking schedules.  [Company] has a policy regarding the mechanic inspecting/certifying/approving the use of medical 'D' O2 bottles to be carried in their approved brackets (which is an FAA waivered practice); but these devices are a compressed vessel not inspected/certified/approved.The only acceptable pressurized vessels we are authorized; besides the medical O2 and fire extinguishers; are those vessels used to inflate rafts/PFD's; provided they are with the raft/PFD. The HEEDS device is not used for this purpose.The rationale that HEEDS bottles should be acceptable since the CO2 'cartridges' used for inflatable life vests is not an appropriate comparison inflatable life vests are governed by a very specific TSO requirement; and were each vest manufactured is  required to be approved by the FAA before it is can be use in an aircraft application.  HEEDS bottles are not 'cartridges' for use in specific applications under an FAA approved TSO.  [Note: Cartridges authorized under 40 CFR 175.10(a)(24) are limit capacity of compressed gas to 50mL (equivalent to a 2.8 g carbon dioxide cartridge); and HEEDS bottle  holds 1.7 liters of 3000 psi]The reality is that the HEEDS bottle is an extra piece of baggage being carried aboard by individuals; and it's a 3000 psi compressed gas cylinder (not cartridge) that is prohibited by our GOM as a Class 2.2 Hazardous Material and where there is not approved waiver for its carriage any approved training program for its use; inspection; orhandling.[Company] OPSPEC AOO4b. The certificate holder is not authorized and shall not :Accept; handle; and carry materials regulated as Hazardous MaterialsSee also 49 CFR 171.8; 49 CFR 175.10; 49 CFR 175.8(b)(1);  49 CFR 175.1Reiterate the HAZMAT policy and alert aircrew members to be wary of carry-on equipment of specialty teams. Have the Safety Department include a specific warning about HEEDS equipment in their safety publications.




Synopsis: EC135 Captain reported becoming aware of a possible hazardous material violation related to aircraft occupants wearing compressed gas bottles as part of their life vest equipment.