1. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 1 Hydrostatic Test Interval of Fire Extinguishers STANDARDIZATION OF HYDROSTATIC TEST INTERVALS FOR FIRE EXTINGUISHERS

2. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 2 Hydrostatic Test Interval of Fire Extinguishers  Goal u Fourteen years Hydrostatic Test Interval for Fire Extinguishers should be allowed for all users.

3. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 3 Hydrostatic Test Interval of Fire Extinguishers  Request u Hydrostatic Test of Halon bottle should be performed not more than necessary u The frequency should be based on maintenance data. u Hydrostatic Test Requirements for Fire Extinguishers must be the same for all users.

4. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 4 Hydrostatic Test Interval of Fire Extinguishers Background Background u The working Group was established in April 1997 u 1999 it was discussed to close the Working Group because of no progress but the members of the IHRWG Meeting decided to continue

5. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 5 Hydrostatic Test Interval of Fire Extinguishers Facts of the past situation Facts of the past situation (1997 - 2002) u 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.

6. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 6 Hydrostatic Test Interval of Fire Extinguishers Quantity of Halon in the Commercial Aircraft fleet

7. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 7 Hydrostatic Test Interval of Fire Extinguishers  Facts of the past situation  Facts of the past situation (1997) u There was 508 tons of Halon in the fleet of Airbus and Boeing (including Douglas Product Division). u 5% of Halon is lost at each overhaul (25,4 tons at each overhaul period). u 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 $

8. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 8 Hydrostatic Test Interval of Fire Extinguishers  Facts of the past situation  Facts of the past situation (1997 - 2002) u If the DOT-E 10990 is changed to allow 14 year interval only u 25,4 tons in stead of 71,1 tons u will be released to the atmosphere. This will prevent release to the atmosphere of 45,7 tons. Valued (45700 X 30 $) = 1 371 000 $

9. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 9 Hydrostatic Test Interval of Fire Extinguishers Present situation of Hydrostatic Test Interval Present situation of Hydrostatic Test Interval The DOT requires in general an interval of 5 years. u The Fire Extinguisher Manufacturers W. Kidde and Pacific Scientific recommend 14 years interval. u 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. u There was a Draft of an FAA Order 8000.40 issue “E” at the FAA WEB, but it is deleted

10. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 10 Hydrostatic Test Interval of Fire Extinguishers  Actions taken since 1997 u IHRWG under the stewardship of Chairman and co-operation of EPA was asked to request DOT to amend the rule. u 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

11. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 11 Hydrostatic Test Interval of Fire Extinguishers  Actions taken since 1997 u The European Airlines under stewardship of the AEA (Association of European Airlines) have made 4 request to the DOT u All requests have been refused

12. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 12 Hydrostatic Test Interval of Fire Extinguishers  Actions of AEA –Request for an Exemption under 49 CFR Subpart B (23.Jun. 2000) F 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 F Letter was lost. No answer. –Same request as above F 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) F Refused. Suggestion: Ask your local Authorities for a release

13. Hans Humfeldt, Lufthansa Technik AG, Meeting in Seattle (12./13. March 2002) 13 Hydrostatic Test Interval of Fire Extinguishers Future Future What shall we do next to reach our purpose?