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Federal Aviation Administration
Washington, DC

MMEL Policy Letter 43, Revision 3

Date:                                          12/04/2017

To:                                             Manager, Aircraft Evaluation Division (AFS-100)
     All Aircraft Evaluation Group Managers

From:                                        Manager, Air Transportation Division (AFS-200)

Reply to Attn of:                       Manager, New Program Implementation Branch (AFS-240)

SUBJECT:                       Crewmember Portable Protective Breathing Equipment (PBE)

MMEL CODE:                        35 (OXYGEN)

REFERENCE:                         PL-43, Revision 2, dated December 18, 2011
                                                 PL-43, Revision 1, dated August 15, 1997
                                                 PL-43, Original, dated March 15, 1990

PURPOSE:

The purpose of this Policy Letter is to establish standard MMEL relief for Portable Protective Breathing Equipment (PBE).

DISCUSSION:

Revision 3: Clarifies PL-43 by adding “Portable” proceeding “Protective Breathing Equipment”. Also clarifies proviso adding “14” proceeding “CFR”, and adds conditions a), b), and c). Adds note advising operators that inoperative PBE unit(s) are subject to dangerous goods shipping and handling requirements if removed from certified location, or are removed from the aircraft. If inoperative PBE unit(s) is removed from certified location, or removed from the aircraft, they are considered “in commerce” and Title 49 of the Code of Federal Regulations (49 CFR) part 175 dangerous goods regulations apply.

Revision 2: Added relief for PBE removed and the requirement to remove or obscure the PBE location placard.

Revision 1: Updated PL-43 to current PL standards. The requirement for portable PBE units for use by crewmembers in combating an in-flight fire became effective January 31, 1990. Airline operators can procure PBE units from several different manufacturers. One distributor, the Puritan-Bennett Aero Systems Company, has informed operators who purchased their crewmember PBE units that a new determination has been made on the serviceability of these units. Based on their test, the vacuum pouch of a Puritan-Bennett PBE unit may be punctured for up to 7 days without degradation of the moisture sensitive chemical in the atmosphere regenerating system. Previous guidance from the company was to replace any unit, in which the vacuum pouch had been punctured, at the first opportunity not to exceed 48 hours.

POLICY:

A punctured PBE seal may reveal damage to other than the regenerating system, such as a torn hood or broken face plate. Any time a PBE seal is broken, the PBE unit is considered inoperable. It is, therefore, necessary to require all crewmember PBE units, required by the Code of Federal Regulations (CFR), to be operable. Crewmember PBE units in excess of those required by CFR may be granted relief.

The following standard MMEL proviso and repair category is adopted to provide standardization among all MMELs.

MMEL TABLE KEY
SYSTEM & SEQUENCE NO.
ITEM
1. REPAIR CATEGORY
2. NUMBER INSTALLED
3. NUMBER REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS

35. OXYGEN

 

Sequence No.

Item

1

2

3

4

Change Bar

XX-X

Portable Protective Breathing Equipment (PBE)

D

-

-

Any in excess of those required by 14 CFR may be inoperative or missing provided:

a)   Inoperative PBE remains in a certified location or is removed from the aircraft,

b)   Location placarding is removed or obscured, and

c)   Required distribution is maintained.

NOTE: Inoperative PBE units removed from a certified location, or removed from the aircraft, are subject to 49 CFR dangerous goods regulations.

 

Each Flight Operations Evaluation Board (FOEB) Chair should review the specific aircraft configuration(s) and apply this policy to affected MMELs through the normal FOEB process.

ORIGINAL SIGNED by

/s/ Stephen C. Moates for

Manager, Air Transportation Division