New Part 91 and oxygen requirements

[Dick Smith]

Do I read the new Part 91 legislation, due to come in on 2 December 2021, correctly regarding supplemental oxygen?

Rather than copy the proven US system, in Australia CASA has come up with a requirement that will add considerably to the cost. That is, they require the aircraft to be fitted with an oxygen system to fly above 10,000 feet, even though they have copied the FAA system in not requiring it to be used up to 12,500 feet.

Can anyone explain why there is such a requirement?

Flying above 10,000 feet quite often gets you above the inversion layer and means the flight is smooth and less fatiguing. It also means better fuel economy and a greater distance to glide if there is an engine failure in a single engine plane.

[KRviator]

We have to have and use O2 above 10,000 now don't we? CAO20.4 refers. So what will change with the new Part 91 rules that isn't already covered under the existing legislation?

[Cloudee]

Do I read the new Part 91 legislation, due to come in on 2 December 2021, correctly regarding supplemental oxygen?

Rather than copy the proven US system, in Australia CASA has come up with a requirement that will add considerably to the cost. That is, they require the aircraft to be fitted with an oxygen system to fly above 10,000 feet, even though they have copied the FAA system in not requiring it to be used up to 12,500 feet.

Can anyone explain why there is such a requirement?

Flying above 10,000 feet quite often gets you above the inversion layer and means the flight is smooth and less fatiguing. It also means better fuel economy and a greater distance to glide if there is an engine failure in a single engine plane.

In the CASA plain English guide to Pt 91 it states oxygen requirements have been relaxed. It then states:

“Supplemental oxygen (MOS 26.43)
An aircraft operated at a pressure altitude above FL 125 must be fitted with supplemental oxygen equipment which can store and dispense the oxygen to crew members and passengers as set out in the following table.”

So as I read it, the new lower limit for oxygen is 12,500 ft. What’s your reference for the 10,000 ft limit?

[Lead Balloon]

You know the answer, Dick.

Australia's air is different.

Australia's pilots are too stupid to make their own decisions about when to use supplemental oxygen (whether above or below 10,000' AMSL up to 12,500' AMSL).

Australia's regulator 'harmonises' by making rules different to the world's biggest and best builder, operator and certifier of aircraft.

We should count ourselves lucky that supplemental oxygen hasn't been mandated for night flights over 6,000' AMSL.

[Dick Smith]

Cloudee, the Part 91 MOS states:

“26.43 Supplemental oxygen

(1) An aircraft operated at a pressure altitude above 10 000 ft (a relevant aircraft) must be fitted with supplemental oxygen equipment capable of storing and dispensing supplemental oxygen to crew members and passengers.”


Here is a link: https://www.legislation.gov.au/Details/F2020L01514/Html/Text#_Toc57289557

[Cloudee]

Soot looks like it’s true, you have to fit oxy equipment if you fly over 10,000 ft but don’t have to use it unless you go higher than 12,500 ft. Another CASA clanger?

Division 26.11 Oxygen equipment and oxygen supplies

26.43 Supplemental oxygen

(1) An aircraft operated at a pressure altitude above 10 000 ft (a relevant aircraft) must be fitted with supplemental oxygen equipment capable of storing and dispensing supplemental oxygen to crew members and passengers.

(2) A relevant aircraft must carry sufficient supplemental oxygen to meet the requirements set out in Table 26.43 (2).

(3) For a person mentioned in column 1 of an item in Table 26.43 (2), supplemental oxygen must be made available through an oxygen dispensing unit (a dispensing unit) in accordance with the supply requirements mentioned for the item in column 2.

(4) Each flight crew member must use the supplemental oxygen that is made available to each of them in accordance with the supply requirements mentioned in column 2 of item 1 of Table 26.43 (2).

Table 26.43 (2) – Supplemental oxygen requirements




Supplemental oxygen supply requirements

1

Flight crew member or cabin crew member

(a) For any period exceeding 30 minutes when the cabin pressure altitude is continuously at least FL 125 but less than FL 140, there must be supply for the entire period.

(b) For any period when the cabin pressure altitude is at least FL 140, there must be supply for the entire period.

(c) Without otherwise affecting paragraphs (a) and (b), when a pressurised aircraft is flown at an altitude of FL 250 or more (relevant flight), there must be at least 10 minutes supply even if the entire period of relevant flight is less than 10 minutes.

2

Passenger

(a) For any period when the cabin pressure altitude is at least FL 150, there must be supply for the entire period.

(b) Without otherwise affecting paragraph (a), when a pressurised aircraft is flown at an altitude of FL 250 or more (relevant flight), there must be at least 10 minutes supply after descending below FL 250 even if the entire period of relevant flight is less than 10 minutes.

[Dick Smith]

Let’s hope it is simply an honest mistake and they will rectify it urgently.

[Ixixly]

What's the clanger here exactly? Seems prudent to me, anything over 10,000ft is definitely a good time to think about getting on oxygen, it's a little hard to do that if you don't have it. Above 12,500ft should definitely be on it just to be on the safe side. If you're getting above 10k then it wouldn't be unexpected to maybe even need an extra 1,000ft or so you weren't expecting to clear the weather and all of a sudden find yourself needing something you don't have.

It also isn't an onerous cost with purchasing a portable system and infact a company could have a handful of portables to cover a fleet and only carry when it looks like it'll be necessary?

[triadic]

An aircraft operated at a pressure altitude above 10 000 ft (a relevant aircraft) must be fitted with supplemental oxygen equipment capable of storing and dispensing supplemental oxygen to crew members and passengers.

Does a portable system meet the requirements?

[Shackeng]

In a previous life as a flying spanner on Beverlys, I couldn’t figure out why I got so tired after pumping oil at about 10,000’. 🤭

[Ixixly]

Does a portable system meet the requirements?

108.26 is still relevant so far as I'm aware, it states: 4.3 Portable oxygen units may be used to meet the crew or passenger breathing requirements.

A Mountain High 02D2 kit with cylinder went for about 2k last I checked.

[Dick Smith]

IxIX- I simply can’t believe your post is genuine!

Do you really believe there is no problem in CASA enforcing an oxygen fitment requirement for aircraft that fly between 10,000 and 12,500 even though there is no requirement to use oxygen?

Do you work for CASA? Have you ever owned or operated an aviation business? Or any business at all ?

[Al E. Vator]

Dick Smith can you stop being a smart arse when somebody says something different to you.

Actually, if what has been presented above is correct, it does seem logical. There are definite effects of lack of oxygen on some people above 10,000ft (some figure has to be chosen and 10,000 is as good as any). Rather than dictating you MUST wear the gear, it is sensible to have it there under 12,500ft (again another figure has to be chosen) in case its needed.

If I were a legislator I'd probably view that as a sensible concept. Like having a first aid kit available. Hope not to use it but it's there if you need.

Having a portable oxygen bottle on board in no way affects the viability of a business, particularly if the oxygen isn't even needed.

So maybe quit being a snide smartypants and accept others may actually have valid opinions.

[Lead Balloon]

So why not, then, mandate carriage and use of oxygen on night flights above 6,000'?

You know you can choose to carry and use oxygen on flights above 1'?

[Squawk7700]

Having a portable oxygen bottle on board in no way affects the viability of a business, particularly if the oxygen isn't even needed.


Oh really?

What about:

- Purchase of the equipment
- Maintenance of the equipment, purging etc
- Testing and certification
- Ops manual additions and approvals
- Training
- Refills (if used)
- Oxygen meters, portable or mounted. LAME work and approvals required for fixed units.
- Sanitisation of the units after use (even if not used in the current Covid climate)
- Reduced payload on aircraft

…. to name just a few.

[SWMBO]

A bit of history on the US regs first, in simple terms. Part 135 ops= above 10k for crew, part 91 ops 12.5k.
Why the difference? It was lobbied by a major group back in the early 70's for the 12,500' for P91 ops to be able to pop up and over mountain ranges in the west of the country. Not stay there all day. This was to save the impost of expensive gear on the private operator. Part 135 is not so accomodating.

Recently, during an FAA FAAST team webinar, FAA personnel and the CEO of AEROX did a great presentation explaining the history and the science behind when you should use it. For most people, even fit and healthy folks, there is a significant cognitive benefit above 8000' and they were recommending despite what the regs say, if you are flying above 8000' for an hour or more you really should be using supplemental O2. For flight at night, vision is greatly enhanced as well as cognitive ability and the recommendation was 5000' and above at night.

I can personally attest to the statements made in that webinar are true as that is exactly consistent with my own testing 10-11 years ago. Myself and most of my flying friends all have O2 systems now. It really is a cheap legal performance enhancing drug!

This link is the same material presented by the "Aerox Dude", this time however for the Cessna Pilots Assoc. It is a long watch but worth doing, especially some of the slides showing FAA data.
Search YouTube for "Complete Guide to Supplemental Oxygen Use for General Aviation "

Also consider the recent Hypoxia event where the pilot should have been using O2 the whole flight. ATSB have a good report on the Caravan that sailed over Brisbane and out to sea.
There are two major suppliers, AEROX and Mountain High. Both are represented in Australia and the Aerox dealer carries stock here.

Dick, I believe that while CASA should do in this instance leave the current rules in place, basically Part 135 style rules. What they mean or should mean is "fitted" includes a portable system such as Aerox or MH.
I assume you have a portable or built in system for your plane, and that you probably would/should be using it above 8000' anyway as the health benefits are well worth it, especially as we get older. What do you have if any, and how do you use it?

[SWMBO]

Squawk7700

Not sure what the business case is here, this is about Part 91. Anyone flying a lot, over longish legs and wanting the altitude, will not find the costs prohibitive.

As I posted above, myself and quite a few friends have adopted this gear as "normal" and the ongoing costs are trivial.

[SWMBO]

And for those looking for a fast track to the links I suggested previously from ATSB and the CPA try these.

https://youtu.be/TEPAprprCSg

and

https://www.atsb.gov.au/media/news-items/2021/fatigue-mild-hypoxia/

[Dick Smith]

It doesn’t pass the commonsense test.

I bet it was a simple error.

If such a requirement is necessary for safety for private operations why wouldn’t the FAA mandate fitment?

They have over ten times the number of aircraft that we have.

Competent pilots I know would not spend excessive time above 10,000 without oxygen but the US regs allow for good judgement.

Lets say you are a farmer living in the outback and visit the coast once a month or so. There will be times when going above 10,000 and getting above the inversion layer would be sensible. But. Hold on you can’t because you do not have an oxygen system fitted!

[Lead Balloon]

Now we're down to 5,000' for night ops, SWMBO?

Here's what the ATSB actually said about the 'recent Hypoxia event':The ATSB found that the pilot was likely experiencing a level of fatigue due to inadequate sleep the night before and leading up to the incident. Further, operating at 11,000 ft with intermittent use of supplemental oxygen likely resulted in the pilot experiencing mild hypoxia. This likely exacerbated the pilot’s existing fatigue and contributed to the pilot falling asleep.I've spent many, many continuous hours cruising over 8,000' without supplemental oxygen without falling asleep or making dumb mistakes (or at least not more dumb mistakes than I usually make under 8,000').

The CEO of AEROX wouldn't have any commercial conflict?

2020 guidance from the FAA (https://www.faa.gov/pilots/safety/pilotsafetybrochures/media/hypoxia.pdf).

[Car RAMROD]

Lets say you are a farmer living in the outback and visit the coast once a month or so. There will be times when going above 10,000 and getting above the inversion layer would be sensible. But. Hold on you can’t because you do not have an oxygen system fitted!

Is the farmer doing flights above 10,000ft now? If so then he will already have oxygen. So come p91 no big change.
New drivers after December will have to suit the new rules.

doesn’t sound like the new rules make it more expensive for the people already doing flights above 10k. Actually, considering they don’t have to use it above 10k (in certain circumstances), you could argue that it’s actually cheaper as they are not using oxygen and refilling bottles.

I wonder if there was resistance to implementing the original oxygen requirement when it first came in?


there is also no definition of “fitted with” in the new regs.
they do however in the plain English guide define “supplemental oxygen” and that is “means oxygen that is provided to an occupant of an aircraft by purpose designed equipment to supplement the oxygen available in the atmosphere inside the aircraft.”

So a purpose made portable bottle and gear carried, I believe, will suit the regs.


is this another mountain out of a molehill again?

[TukwillaFlyboy]

Is the farmer doing flights above 10,000ft now? If so then he will already have oxygen. So come p91 no big change.
New drivers after December will have to suit the new rules.

doesn’t sound like the new rules make it more expensive for the people already doing flights above 10k. Actually, considering they don’t have to use it above 10k (in certain circumstances), you could argue that it’s actually cheaper as they are not using oxygen and refilling bottles.

I wonder if there was resistance to implementing the original oxygen requirement when it first came in?


there is also no definition of “fitted with” in the new regs.
they do however in the plain English guide define “supplemental oxygen” and that is “means oxygen that is provided to an occupant of an aircraft by purpose designed equipment to supplement the oxygen available in the atmosphere inside the aircraft.”

So a purpose made portable bottle and gear carried, I believe, will suit the regs.


is this another mountain out of a molehill again?

Yes, but thats how he rolls….

[Ixixly]

Oh really?

What about:

- Purchase of the equipment
About $1.5-2k for a full MH 02D2 system with cylinder, brand new
- Maintenance of the equipment, purging etc
Extremely trivial, especially if you're not using it often and use a portable system
- Testing and certification
Why would we need to test and certify a portable system?
- Ops manual additions and approvals
Hardly a gargantuan effort.
- Training
For an O2D2 system? 15mins to show someone how to use it. Another 15mins if they'll be filling the bottles themselves, less if they plan to get someone to do it for them each time.
- Refills (if used)
Barely an issue, plenty of places can fill up an O2 tank, even if you're regional you'll find it without a lot of hassle, go chat to your local GP or Clinic, they'll probably be all too happy to fill up a small bottle from their own as it'll take 1/5th of bugger all of the large tanks they've got. I know I never had any real issues and even a small cylinder will go for a long time with an O2D2.
- Oxygen meters, portable or mounted. LAME work and approvals required for fixed units.
Portable system, on the cylinder, no worries.
- Sanitisation of the units after use (even if not used in the current Covid climate)
Keep your own cannula and a few spares, they're only a few dollars each, usually comes with 2-4 in those kits.
- Reduced payload on aircraft
You mean the kilogram or so for a small bottle and system? Have a light lunch.

…. to name just a few.

Please, do name some more for us?

Once again, I don't see this as that much of an imposition. If you're a Pilot planning to be above 10k regularly you should be thinking about having this onboard anyway, it's not expensive, it's dead simple to use and it gives you lots of options one day when you need/want them. Got some weather coming up ahead and an extra couple of thousand feet will clear you? No worries, grab the oxy, put it on, climb up and happy days. Going on a night flight? Well you're well aware of the affects above 6k, now you don't have to worry at all, take your system, have a few puffs once in a while and you're golden and ready to tackle it.

Not planning on going above 10k very often? Got some friends around that also have Aircraft? Why not go in on a portable that you keep around that everyone can borrow! Why not ask the local Aero Club if they'd purchase a couple that they can then rent out to the locals instead? They probably want them too.

[SWMBO]

Now we're down to 5,000' for night ops, SWMBO?

Here's what the ATSB actually said about the 'recent Hypoxia event':I've spent many, many continuous hours cruising over 8,000' without supplemental oxygen without falling asleep or making dumb mistakes (or at least not more dumb mistakes than I usually make under 8,000').

The CEO of AEROX wouldn't have any commercial conflict?

2020 guidance from the FAA (https://www.faa.gov/pilots/safety/pilotsafetybrochures/media/hypoxia.pdf).


Yes, above 5000' at night you would be amazed by the performance improvement. See, unless you have been there and done that, and actually tested it with/without you would not only not know, but not appreciate the difference. For the avoidance of doubt, I am not advocating for more regs. Just pointing out the real world facts for others to make prudent decisions. Try it yourself, there is bound to be an APP you can use, do a cognitive test at home, then try doing another at 9500'. Not everyone is the same. The people living in Vail CO will do a lot better than us down here I bet.

The webinar I watched last year on this was one where he was invited by the FAA FAST program guys, because he and his engineering employee were subject matter experts, which they would be, I am sure you would agree. So the fact he also has a commercial interest, which he does, is rather irrelevant when he was invited by them to do the tutorial. Cessna Pilots folk obviously thought it was good too.

Lean Balloon, you did not watch the video nor study the graphs did you? No. Obviously not, because your post was minutes after mine. No way you could have found all the gems in that video in 3 minutes. I couldn't having seen it a year ago either. In the interests of education, just watch it, learn from it and ignore it if you wish. Nobody is forcing this on anyone. Although I am a big supporter of using it.

ATTN: DICK SMITH
Maybe you missed my post. You are probably correct there is a typo, what the FAA regs require and what CASA are suggesting is "having and using" not having to go out and spend $10K on a plumbed in system. Portables will be 100% OK. I may be wrong, in which case CASA are more stupid than we all already knew.

Dick, do you use any supplemental O2? Is it fixed installation or portable? If so, do you notice a benefit?

[Lead Balloon]

Did you read the FAA guidance - dated 2020 - at the link in my post?

But at least you're not advocating for more regs. Thank heavens for that.

As you say, 'not everyone is the same' and, hopefully, Australian pilots will eventually become smart enough and trustworthy enough to make the decision themselves, on the basis of their particular circumstances, about the day/night below 12,500' use of supplemental oxygen. I can but dream.

Just for the record: You don't have any direct or indirect commercial interest in the sale of portable supplemental oxygen systems, do you?

[Pinky the pilot]

After reading all the previous posts, and then reminiscing on my time flying high time, beat up Bongo Vans and A model C402's around the PNG landscape at high altitudes......:ugh:

How on earth did I ever survive????:ooh::hmm:

And I was only there for a relatively short time! What a pity the 'Chuckling Chimbu' no longer frequents this site, as I'd love to read his opinion on this subject!

And to any of those who look for ways to be offended/upset/irate/whatever, not that such people frequent this site:}; I do not neccessarily condone or support any of the practises carried out in that place way back then!

It was just that that was the way it was!:=

[Cloudee]

Cloudee, the Part 91 MOS states:




Here is a link: https://www.legislation.gov.au/Details/F2020L01514/Html/Text#_Toc57289557

CASA has gone to great expense to put out a plain English guide to part 91 (available in print and online ).
https://www.casa.gov.au/sites/default/files/peg-part-91-v1-interactive-version.pdf. Page 143.

It states there is a requirement for oxygen above FL125, no mention at all of any 10,000 ft limit that I could find.

“Supplemental oxygen (MOS 26.43)
An aircraft operated at a pressure altitude above FL 125 must be fitted with supplemental oxygen equipment which can store and dispense the oxygen to crew members and passengers as set out in the following table.
Each flight crew member must use the supplemental oxygen as described the following Table.”

There it is, in plain English, published by the regulator, that’s good enough for me.

[340drvr]

I'd agree, if "fitted" with supplemental oxygen equipment actually means a plumbed-in or factory installed system, compliance would be extremely onerous.
But, let me ask an innocent question, from FAA-land. On a practical basis, how often do small-plane GA flights in Australia actually fly over 12500 ft,, or even 10,000 ft.? With the highest peak at 7300 ft or so, do many flights ever go that high? Maybe to get out of weather/icing, etc., or to get above thermal bumps on a hot afternoon? In the US, in the east, most flights don't ever need to go that high, but out west, and around the mountains, it's quite common for owners to have turbocharged aircraft, and to fly at 12,000 or higher. And, many IFR routes in the mountains may have MEAs of 15,000. I'm genuinely curious in the comparison between ops here and there, thanks.

[Lead Balloon]

CASA has gone to great expense to put out a plain English guide to part 91 (available in print and online ).
https://www.casa.gov.au/sites/default/files/peg-part-91-v1-interactive-version.pdf. Page 143.

It states there is a requirement for oxygen above FL125, no mention at all of any 10,000 ft limit that I could find.

“Supplemental oxygen (MOS 26.43)
An aircraft operated at a pressure altitude above FL 125 must be fitted with supplemental oxygen equipment which can store and dispense the oxygen to crew members and passengers as set out in the following table.
Each flight crew member must use the supplemental oxygen as described the following Table.”

There it is, in plain English, published by the regulator, that’s good enough for me.Did you read the 'plain English' disclaimer at the beginning of the guidance? ...This guide should not be used as a substitute for the aviation regulations or MOS...Not surprising. The law's the law and the guidance ain't.

[Cloudee]

Did you read the 'plain English' disclaimer at the beginning of the guidance? Not surprising. The law's the law and the guidance ain't.

I’ll explain to the magistrate that I’m a dumb pilot and not a lawyer and say CASA told me this via their website:

“We have developed a Plain English Guide to make it as easy as possible to understand the new general operating and flight regulations for all pilots.

The guide contains the general operating and flight rules you need, including some helpful hints that explain what’s expected of you and what you might need to consider when complying with the rules.

The Plain English Guide sets out the regulatory requirements of the Part 91 Civil Aviation Safety Regulations and the associated Manual of Standards in a concise, clear easy to read and practical format.”

I’ll take my chances.

Plain English Guide for new flight operations regulations | Civil Aviation Safety Authority (casa.gov.au) (https://www.casa.gov.au/publication/plain-english-guide-new-flight-operations-regulations)

[Car RAMROD]

It would be nice to hop over a bit of occasional fluff and ice at 10K for a few minutes without all of that paraphernalia and expense.

You can’t do that right now without oxygen.

the new rules will allow you to, but you’ll have to carry it (and use it in certain circumstances).

sounds like an improvement.

[aroa]

Not sure about going to yr local welder for oxygen.!
For survey ops above 10 k we had a base bottle, and chased up in the field, medical dry breathing oxygen.
See the local hospital
Moisture free for cold lines. And portable bottles.
In Oz it’s above 10, US above 121/2. Skydiving short term to 14.
And Ww1 pilots went to 20k to get above the opposition !

[KRviator]

Serious question:

Does anyone have, or have practical experience in using, one of the portable oxygen concentrators, such as the Innogen G3? There was a writeup in KitPlanes about them several years ago and how having a limitless supply of oxygen changes your view of onboad O2 such that you're now more likely to actually use it when you otherwise wouldn't, like above 10,000 but for 'only' 20 minutes, or above 5,000 at night.

From what I can see looking at CAO108.26 portable O2 systems can be used so long as they can meet the mass flow requirements specified in that order, but unless you're flying high solo regularly, it would be a fairly expensive exercise to fit a 4-seater with these things...

[spektrum]

Oh look, another thread where sheeple actually advocate for more government tyranny by the way of red tape. Allow me to take my black dog to the vet.

[Old Akro]

Ixixly said "Once again, I don't see this as that much of an imposition.".

I also wonder if you have flown at 10,000 ft. Previously, you could cruise at (say) 10,000ft, then pop up to 10,500 or 11,000 ft (subject to the transition layer) for a short period without oxygen to get over a buildup. Now you cant.

I agree its prudent to use oxygen early if you are going high. I'll often use it above 8,000 ft. But, prudence and mandatory regulation are 2 different things. When I did my hypoxia training (have you done that Ixixly?), I did an added segment where I operated at a simulated 14,000 ft for 30 minutes. At that density altitude your judgement is slightly impaired, but there are many circumstances where its a whole lot safer than punching into weather. Why can I not use judgement without running the gambit of CASA's strict liability regulations.

A favourite quote at the moment is from Les Abend from Flying magazine (quoted by Chesney Sullenburger in his book) which is along the lines that pilots are selected for their knowlege and experience, but assessed for their compliance. Its time CASA allowed us to excercise knowledge & expereience again.

Also, (unlike the USA), we cannot simply go and buy a portable system. The removeable / portable system in Australia requires an STC and flight manual supplement for the specific aircraft - hence another round of engineering order & flight manual revision costs on top of the oxygen system. We need the USA style expemtion from engineering orders for minor modifications.

.

[Old Akro]

Its worth noting that the only reason we nominate an altitude is as a metric for SPO2 levels. A better yardstick would be density altitude, best still would be SPOs2 levels. When these regulations were formed, pulse oximiters were not readily available. Now they are everywhere. I challenge anyone to find a definitive limit for SPO2 readings. I've looked & looked. This is partly because its a personal thing that varies. I have a figure that I usdes as a minimum. I also find that I need higher oxyhen flows to maintain this than the oxygen regulator (maked in feet altitude) suggests. I also use a pulse oximiter that I calibrated against the lab gear when I did hypoxia training. But it would be pretty easy to suggest that (say) the crew SPO2 reading must remain above 90%. Why cant we be having regulations that are keep up with contemporary technology?

[Check_Thrust]

I also wonder if you have flown at 10,000 ft. Previously, you could cruise at (say) 10,000ft, then pop up to 10,500 or 11,000 ft (subject to the transition layer) for a short period without oxygen to get over a buildup. Now you cant.

When could you previously "pop up above 10,000ft without oxygen"? For quite some time now I believe the CAO has stated that in an unpressurised a pilot must be provided with and use supplemental oxygen when above 10,000ft.

Provided the flight did not exceed FL140 and the time above 10,000ft did not exceed 30 minutes the passengers do not require oxygen. (Is that what you might be referring to?)

I note that you said "pop up" and not "cruise" but if your intent was to level off at 10,500ft for a short duration when have you been allowed to do that either as one is not permitted to cruise within the transition layer?

[TukwillaFlyboy]

A simple google search will show that there is a wide body of academic ( I know thats not your thing Dick) support for setting 10,000 ft as a limit for
non-assisted flight. Its supported by experimentation. And regulators have to publish a number. Pilots are expected to comply with regulations for pretty obvious reasons.
Personally I have been to high altitude in Nepal and seen fellow trekkers start falling over at as low as 12,000 ft.
And they don’t realise its happening ! Thats the point. Don’t self regulate. Just follow the rules.

[Dick Smith]

Come on Tukwila I was one of the founders of the Australian Skeptics. I have always supported the scientific approach.

It’s about balancing advantages and disadvantages. There are times when flying above 10,000 gives a safety advantage.

[roundsounds]

Dick Smith can you stop being a smart arse when somebody says something different to you.

Actually, if what has been presented above is correct, it does seem logical. There are definite effects of lack of oxygen on some people above 10,000ft (some figure has to be chosen and 10,000 is as good as any). Rather than dictating you MUST wear the gear, it is sensible to have it there under 12,500ft (again another figure has to be chosen) in case its needed.

If I were a legislator I'd probably view that as a sensible concept. Like having a first aid kit available. Hope not to use it but it's there if you need.

Having a portable oxygen bottle on board in no way affects the viability of a business, particularly if the oxygen isn't even needed.

So maybe quit being a snide smartypants and accept others may actually have valid opinions.

If someone disagrees with your opinion and offered theirs, it doesn’t mean they’re a smartarse. Surely we are mature enough to have a robust discussion / debate?

[roundsounds]

Dick Smith can you stop being a smart arse when somebody says something different to you.

Actually, if what has been presented above is correct, it does seem logical. There are definite effects of lack of oxygen on some people above 10,000ft (some figure has to be chosen and 10,000 is as good as any). Rather than dictating you MUST wear the gear, it is sensible to have it there under 12,500ft (again another figure has to be chosen) in case its needed.

If I were a legislator I'd probably view that as a sensible concept. Like having a first aid kit available. Hope not to use it but it's there if you need.

Having a portable oxygen bottle on board in no way affects the viability of a business, particularly if the oxygen isn't even needed.

So maybe quit being a snide smartypants and accept others may actually have valid opinions.

If someone disagrees with your opinion and offered theirs, it doesn’t mean they’re a smartarse. Surely we are mature enough to have a robust discussion / debate?

[Lead Balloon]

If this is based on science and if regulation is required, the regulation would be a requirement that deals with the risk: There would be a mandated minimum SPOs2 level.

Old Akro noted the solution earlier, which solution private pilots in the USA chose to take years ago.

Sadly, Australian pilots are apparently too stupid to do the same and the regulator wouldn’t know how to write an outcome-based regulation even if it bit the regulator on the pitot probe.

[Ixixly]

Ixixly said "Once again, I don't see this as that much of an imposition.".

I also wonder if you have flown at 10,000 ft. Previously, you could cruise at (say) 10,000ft, then pop up to 10,500 or 11,000 ft (subject to the transition layer) for a short period without oxygen to get over a buildup. Now you cant.

I agree its prudent to use oxygen early if you are going high. I'll often use it above 8,000 ft. But, prudence and mandatory regulation are 2 different things. When I did my hypoxia training (have you done that Ixixly?), I did an added segment where I operated at a simulated 14,000 ft for 30 minutes. At that density altitude your judgement is slightly impaired, but there are many circumstances where its a whole lot safer than punching into weather. Why can I not use judgement without running the gambit of CASA's strict liability regulations.

A favourite quote at the moment is from Les Abend from Flying magazine (quoted by Chesney Sullenburger in his book) which is along the lines that pilots are selected for their knowlege and experience, but assessed for their compliance. Its time CASA allowed us to excercise knowledge & expereience again.

Also, (unlike the USA), we cannot simply go and buy a portable system. The removeable / portable system in Australia requires an STC and flight manual supplement for the specific aircraft - hence another round of engineering order & flight manual revision costs on top of the oxygen system. We need the USA style expemtion from engineering orders for minor modifications.

.

I have infact, I've done it quite a few times and personally know I can get to 18k without having any serious effects but I've also done a lot of long-distance running and know that is far from the norm. I've also spent quite a bit of time sitting above 20k in unpressurised Aircraft on portable systems. You've just said yourself that you believe it's prudent to use it above 8k, so we have some agreeance there, the issue isn't with people like you or me that have done hypoxia training and operated at higher altitudes so, therefore, get it, the problem is those that think it's no big deal and therefore don't need to worry about oxygen. That is why regulation like this is put in. It is unfortunate to need these regs, but if everyone practiced common sense all the time we wouldn't need any rules or regs to have standards at all.

From CASAs perspective they know there are plenty of Pilots punching higher to get better weather/winds which is great but they also know there are likely to be plenty thinking "I'll just go to 10k and she'll be right, don't need no oxygen" then find themselves at 12k as they needed that little extra and then find themselves stuck above that without oxygen and no hypoxia training or real understanding of the effects it's having on them.

I don't remember requiring any STC or Flight Sup for portable oxygen either, if it matters we used the Mountain High Portable Kits, maybe some other type needs it?

[Ixixly]

Not expensive? The cost of maintaining a simple plumbed in system in something like a Cessna turbo single is unbelievable. The bottle and regulator have to be overhauled every 3 years and costs circa $4K and there’s only about one place in the country that can do it…. (And don’t they know it!) The green bottle has a life of 14? years and about $8k to replace. Whilst your local welder might be happy to fill up your portable bottle for a beer or two, a plumbed in system done in the aircraft can be $200 a shot from your authorised aviation oxy supplier. Dead simple? Maybe, but oxygen can be quite dangerous and some knowledge and precautions are necessary. It would be nice to hop over a bit of occasional fluff and ice at 10K for a few minutes without all of that paraphernalia and expense.

Way to cherry-pick what I said there. I was specifically talking about portable systems there. I even went and added all the costs and such. It's hard to have a proper, robust discussion when people clearly choose not to read what's been said, it's a real concerning confirmation bias there.

[Captain Sherm]

What response did you get when you queried this during the Consultation period?

[island_airphoto]

From the USA this look nuts - why mandate O2 to be there to look at but not use?
OTOH - I just flew a 3,000 mile delivery with a lot of time at 9500 and 11500. I would have used O2 if I had it, my pulse-ox was in the mid to high 80s and it was fatiguing. I think I was better at high altitude flying when I was in my 20s, but maybe not so much anymore.

[Ixixly]

From the USA this look nuts - why mandate O2 to be there to look at but not use?
OTOH - I just flew a 3,000 mile delivery with a lot of time at 9500 and 11500. I would have used O2 if I had it, my pulse-ox was in the mid to high 80s and it was fatiguing. I think I was better at high altitude flying when I was in my 20s, but maybe not so much anymore.

So you're asking us why mandate it when you yourself just did a rather large delivery flight with a lot of time over 10k feeling fatigued with your pulse-ox going into the mid 80s and didn't take any O2 to use? Perhaps to force people just like yourself to have it there and use it to reduce a fatigue factor that was easily within your control?

[island_airphoto]

So you're asking us why mandate it when you yourself just did a rather large delivery flight with a lot of time over 10k feeling fatigued with your pulse-ox going into the mid 80s and didn't take any O2 to use? Perhaps to force people just like yourself to have it there and use it to reduce a fatigue factor that was easily within your control?
But you are NOT mandating USING it, just carrying it around. We actually tried really hard to get O2 for the delivery and it proved impossible, no one seemed to have it and the one place that finally did got the tanks to the FBO in California about the time we ended up in Maryland 3,000 miles away.

[Ixixly]

But you are NOT mandating USING it, just carrying it around. We actually tried really hard to get O2 for the delivery and it proved impossible, no one seemed to have it and the one place that finally did got the tanks to the FBO in California about the time we ended up in Maryland 3,000 miles away.

Nope, but the mandate would have meant that for your flight you would have had to delay until the O2 was delivered then you would have had it to use to mitigate that fatigue you mentioned. The fact is without a mandate like this you were legally able to depart on a flight that you willingly acknowledge afterwards had a fatigue factor you could have mitigated by delaying by a day or two.

[MJA Chaser]

"All three come from thesame tank of liquid oxygen"

Always have been. Its the way the container (cylinder or tank) is handled and filled that differs so the specifications of the contets which vary between industrial, scientific, medical etc are met.

[lucille]

The need for supplemental O2 is an interesting one. How and why did they choose 10,000 or 12,500 PA as the cutoff? Why not 8,000? Which is the cabin altitude limitation of pressurised aircraft. Or why not say 19,000? which about the height of Mt Kilimanjaro which hundreds of trekkers ascend every day.

[Pinky the pilot]

Or why not say 19,000? which about the height of Mt Kilimanjaro which hundreds of trekkers ascend every day.

Someone should have a talk with Reinhold Messner.

[Dick Smith]

I flew my C208 into La Paz airport and landed at 13,200’ with my oxygen mask on then hired a rental vehicle that had no oxygen. !

[Ixixly]

I flew my C208 into La Paz airport and landed at 13,200’ with my oxygen mask on then hired a rental vehicle that had no oxygen. !

Were you planning to operator this hire vehicle at around 150kts without the opportunity to pull over to the side if you were feeling unwell? If not then this is a pretty poor example and I honestly expect better of you Dick.

[Squawk7700]

Were you planning to operator this hire vehicle at around 150kts without the opportunity to pull over to the side if you were feeling unwell? If not then this is a pretty poor example and I honestly expect better of you Dick.

Hardly fair. That hire vehicle could have just as well been a minivan full of people. The other issue is that you don’t necessarily know that you’re feeling the effects of a lack of oxygen until you drive off the side of the cliff due to your poor judgement.

[Lead Balloon]

It's that air gap between the rubber and the ground that creates all the risk.

I realise it makes us feel good, Ix, to believe that aviation is extraordinarily complex and pilots need to be mini superpeople to be able to cope, thus justifying so much regulation. But, seriously, this is the 21st century and we're not talking about 747s or 380s or Space Shuttles.

[TukwillaFlyboy]

I flew my C208 into La Paz airport and landed at 13,200’ with my oxygen mask on then hired a rental vehicle that had no oxygen. !

Then you were lucky not to suffer altitude sickness.
Reputable trekking companies in Nepal warn trekkers of symptoms above 10,000 ft and most will organise acclimatisation days of rest at around 12,000 ft. It is common for trekkers to fall over if the try to climb too high too fast.
I haven’t climbed Everest but I have been to high altitude in Nepal and I wouldn’t like to try to pass any serious psychometric test at 13,200 ft without acclimatisation.
You weren’t being clever Dick.
Just stupid.
.

[TukwillaFlyboy]

Someone should have a talk with Reinhold Messner.

Messner and Habeler both report hallucinations, out-of-body sensations and “phantom companion” experiences.
Close friends say that neither was the same afterwards.
Anybody who has attempted high peaks will tell you its mostly about enduring misery.

[Ixixly]

It's that air gap between the rubber and the ground that creates all the risk.

I realise it makes us feel good, Ix, to believe that aviation is extraordinarily complex and pilots need to be mini superpeople to be able to cope, thus justifying so much regulation. But, seriously, this is the 21st century and we're not talking about 747s or 380s or Space Shuttles.

Nothing really extraordinarily complicated about it, but a damned sight more complicated than jumping in the car and going for a spin and comparing the 2 as if it proves some kind of point is utterly ridiculous.

[Pinky the pilot]

Messner and Habeler both report hallucinations, out-of-body sensations and “phantom companion” experiences.
Close friends say that neither was the same afterwards.
Anybody who has attempted high peaks will tell you its mostly about enduring misery.

Doesn't surprise me in the slightest. Especially the misery bit. Knew a LAME back in the mid 80's who did some serious climbing and he said much the same thing.

You still around, Kenya?

[Lead Balloon]

Nothing really extraordinarily complicated about it, but a damned sight more complicated than jumping in the car and going for a spin and comparing the 2 as if it proves some kind of point is utterly ridiculous.Indeed. And you get the amount of regulation you crave. Enjoy.

[Dick Smith]

I drove the car and somehow I did not crash or cause an incident and I am still alive today.

[Dick Smith]

Most importantly how does the US with 12 times as many pilots get away without having mandatory oxygen systems installed for aircraft that fly to 12,500’?

Do Americans need less oxygen? A bit like the Sherpa nation!

[TukwillaFlyboy]

I drove the car and somehow I did not crash or cause an incident and I am still alive today.

Which proves precisely what ?
You have no idea how impaired you were.
So .05 is stupid because most drunks get home 90% of the time?
And you were Chairman of CASA……….
You are bringing back lots of bad memories.
Retire gracefully Dick.
You’re embarrassing yourself.

[Dick Smith]

It shows that a healthy human can operate at 12,500 without additional oxygen.

If this what not so the FAA would follow the more restrictive Australian rules.

[Car RAMROD]

It shows that a healthy human can operate at 12,500 without additional oxygen.

If this what not so the FAA would follow the more restrictive Australian rules.

healthy humans have climbed Everest with no oxy.

I know, if they can do that, why bother at all in aeroplanes? We don’t need it!


oh yeah. ‘Murcia!
will you advocate for their gun rules here too please Dick? I want to go hunting with semi auto ARs!

[Ixixly]

Most importantly how does the US with 12 times as many pilots get away without having mandatory oxygen systems installed for aircraft that fly to 12,500’?

Do Americans need less oxygen? A bit like the Sherpa nation!

I don't know Dick, I don't have the Stats, do we fly further, longer and higher than the average US flight? What's the average age of an Aircraft in Australia compared to the US? Do they have better Radar and ATC coverage than we do? Are there any other relevant stats that might mean we're more likely to need this? Without these stats I can't really answer your question and I doubt anyone here has them or could really answer it except with some anecdotal waffle. What I do see is a requirement that doesn't seem to add a huge imposition and would have a positive impact.

[Dick Smith]

The old furphy of the US radar coverage effecting just about every regulation in Aus including oxygen level requirements.

[megan]

Recently, during an FAA FAAST team webinar, FAA personnel and the CEO of AEROX did a great presentation explaining the history and the science behind when you should use it. For most people, even fit and healthy folks, there is a significant cognitive benefit above 8000' and they were recommending despite what the regs say, if you are flying above 8000' for an hour or more you really should be using supplemental O2. For flight at night, vision is greatly enhanced as well as cognitive ability and the recommendation was 5000' and above at night.Some one has to set a standard that encompasses all possible levels of fitness, we fit young military aviators in 1967 were required to use oxygen above 5,000 at night versus 10,000 day. Thanks SWMBO for explaining the reasoning why.

[Lead Balloon]

So, for all those craving a rule:

Why, in the 21st century, isn't the rule a prescribed blood oxygen level (or prescribed blood oxygen level for night ops and a prescribed blood oxygen level for day ops, if the science supports the difference)?

A pilot's blood oxygen level is easily and cheaply measured, continuously, in the 21st century. If a pilot can't be trusted to maintain those levels, why can pilots be trusted to use mandatorily-fitted or carried oxygen supplies?

[megan]

Why, in the 21st century, isn't the rule a prescribed blood oxygen level (or prescribed blood oxygen level for night ops and a prescribed blood oxygen level for day ops, if the science supports the difference)?
People who smoke may have an inaccurately high pulse ox reading. Smoking causes carbon monoxide to build up in your blood. A pulse ox can’t tell the difference between this other type of gas and oxygen may be one reason, that carbon monoxide could very well be coming from your exhaust system. Cold extremities and dark nail polish can also cause false low readings.

[Noeyedear]

The reason for difference ‘base’ level for O2 between Oz and the USA is pretty simple and its a concept Mr Smith should understand, “Affordable Safety”.

You can fly around in Oz at 8,000’ and not hit a damn thing. There’s an awful lot of terrain above 10,000’ in the USA. Flying above 10,000’ but below 12,5000’ allows people in many areas of the USA to go flying without the expense of installing an O2 system.

The next fact is that you will have better O2 blood saturation at 10,000’ than 12,500’ feet. That’s incontrovertible. The level of impairment an individual may suffer, well that’s individual, but again, its a cost/benefit analysis isn’t it?

In Australia, there’s no pressing need to be above 10,000’ in your average piston engined single.

What’s the real benefit of cruising at 12,000’ compared to 10,000’ versus a possible hull loss from a hypoxic episode? Risk management 101.

[Dick Smith]

Quite often the inversion layer sits at about 10,000’ so it is far smoother to fly above it - even if it’s only for 30 minutes to give the pax a rest!

Less fuel usage meaning saving money and less carbon in the atmosphere!

Greater gliding range if an engine failure over tiger country.

The pilot should be in a position to make a decision on this.

[MJA Chaser]

People who smoke may have an inaccurately high pulse ox reading. Smoking causes carbon monoxide to build up in your blood. A pulse ox can’t tell the difference between this other type of gas and oxygen may be one reason, that carbon monoxide could very well be coming from your exhaust system. Cold extremities and dark nail polish can also cause false low readings.
And skin colour ..... Lots of reasons why a pulse oximter can be a fair bit out. Fractional Vs Functional etc etc etc

[Ixixly]

So, for all those craving a rule:

Why, in the 21st century, isn't the rule a prescribed blood oxygen level (or prescribed blood oxygen level for night ops and a prescribed blood oxygen level for day ops, if the science supports the difference)?

A pilot's blood oxygen level is easily and cheaply measured, continuously, in the 21st century. If a pilot can't be trusted to maintain those levels, why can pilots be trusted to use mandatorily-fitted or carried oxygen supplies?

Not to mention that if you're on oxygen with a proper oxygen system then measuring your oxy levels should only confirm that yes, you're breathing oxygen. You're also now talking about a rule that DOES mandate having to use it, this rule mandates having to carry it which is far easier to check has been complied with.

Also no one is "Craving" a rule as you seem to think. A lot of us are pointing out that this particular rule isn't that onerous and has valid justification. If you're not prepared to compromise and accept some level of new rules to come about then to be perfectly honest you shouldn't be involved in any discussion involving Aviation Safety as times change, tech changes, and therefore the rules must change with them. We've got Aircraft now that are far more capable of getting above 10k and being there for a long time thanks to companies like Cirrus for example and as such the rules need to acknowledge this.

Dick, you yourself have just proven the point by using your own C208 as an example and the ability to get into a place like La Paz. You also talk about the Pilot being in a position to make this decision, not really a decision if you're wanting to go above 10k but didn't bring any oxygen with you and don't really spend any time up there and have never completed and high altitude courses is it?

Does CASA bring in mindless, stupid rules that we should rally against? Absolutely, but this is not one of them and if we don't choose our battles we end up looking stubborn and belligerent which only makes our lives more difficult in the end trying to fight against the ridiculous rules that do come about.

[Lead Balloon]

If you're not prepared to compromise and accept some level of new rules to come about then to be perfectly honest you shouldn't be involved in any discussion involving Aviation Safety as times change, tech changes, and therefore the rules must change with them.Well pardon me for having an opinion!

What changes in times and tech does mandatory carriage above 10,000' reflect, justifying a change in rules? It's the same air we're flying in and the same supplemental oxy we are and are not breathing as we were 50 years ago. There have been for many decades, many, many GA aircraft that were and remain capable of going waaaay over 10,000' and cruise there for a long, long time.

The experiment has been run in the USA and the results are in.

Maybe some of us understand the risk, are perfectly able to and responsibly do mitigate the risk effectively, without a new rule.

Once we all give ourselves a collective pat on the back when the new rule is made, how are we going to confirm that people are using the oxygen?