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New Part 91 and oxygen requirements

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New Part 91 and oxygen requirements

Old 14th Jul 2021, 04:23
  #21 (permalink)  
 
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Originally Posted by Dick Smith View Post

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?

Last edited by Car RAMROD; 14th Jul 2021 at 04:49.
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Old 14th Jul 2021, 04:57
  #22 (permalink)  
 
Join Date: Apr 2021
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Originally Posted by Car RAMROD View Post
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….
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Old 14th Jul 2021, 06:10
  #23 (permalink)  
 
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Originally Posted by Squawk7700 View Post
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.
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Old 14th Jul 2021, 06:54
  #24 (permalink)  
 
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Originally Posted by Lead Balloon View Post
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.

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?
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Old 14th Jul 2021, 08:50
  #25 (permalink)  
 
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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?
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Old 14th Jul 2021, 09:46
  #26 (permalink)  
Man Bilong Balus long PNG
 
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Location: Now officially on Life's scrap heap, now being an Age Pensioner and not liking it one little bit! I'd rather be flying but in the meantime still continuing the never ending search for a bad bottle of Red!
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Devil

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......

How on earth did I ever survive????

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!
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Old 14th Jul 2021, 11:42
  #27 (permalink)  
 
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Originally Posted by Dick Smith View Post
Cloudee, the Part 91 MOS states:




Here is a link: https://www.legislation.gov.au/Detai...t#_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/defaul...ve-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.
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Old 14th Jul 2021, 12:12
  #28 (permalink)  
 
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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.
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Old 14th Jul 2021, 12:15
  #29 (permalink)  
 
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Originally Posted by Cloudee View Post
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/defaul...ve-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.
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Old 14th Jul 2021, 12:35
  #30 (permalink)  
 
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Originally Posted by Lead Balloon View Post
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)
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Old 14th Jul 2021, 13:09
  #31 (permalink)  
 
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Originally Posted by Clearedtoreenter View Post
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.
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Old 14th Jul 2021, 13:45
  #32 (permalink)  
 
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In cruise at FL370 and above, in the B737, the cabin altitude sits around 7,500 to 8000 feet. I flew that way since 1990.
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Old 14th Jul 2021, 22:12
  #33 (permalink)  
 
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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 !
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Old 14th Jul 2021, 23:06
  #34 (permalink)  
 
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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...
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Old 15th Jul 2021, 00:44
  #35 (permalink)  
 
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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.
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Old 15th Jul 2021, 02:14
  #36 (permalink)  
 
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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.

.
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Old 15th Jul 2021, 02:33
  #37 (permalink)  
 
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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?
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Old 15th Jul 2021, 05:31
  #38 (permalink)  
 
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Originally Posted by Old Akro View Post
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?
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Old 15th Jul 2021, 05:44
  #39 (permalink)  
 
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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.
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Old 15th Jul 2021, 06:18
  #40 (permalink)  
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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.


Last edited by Dick Smith; 15th Jul 2021 at 06:34.
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