It was at 4,500 feet on a dark night near Purcell, OK, when the rear seat passenger of a Piper Warrior noticed the seat getting warm and the smell of smoke. Very quickly, the passengers found themselves attempting to control an in-flight fire with blankets and bottled water as the pilot put the plane down on an Interstate highway. Everyone cleared the aircraft and watched the cabin section burn … there was no fire extinguisher aboard.
It’s stories like that remind us of the importance of a fire extinguisher aboard an airplane. While the need for a fire extinguisher is well understood, the proper installation and maintenance of onboard fire extinguishers isn’t understood nearly as well. There’s sound reason for ensuring proper maintenance is accomplished ‘cause when you need a fire extinguisher in flight — you need it bad.
It may surprise some that, for Part 91 operations, fire extinguishers aren’t a mandatory piece of equipment on most aircraft … which means without a requirement there isn’t specific guidance regarding what you should have on the aircraft for fire fighting. For the prudent pilot, this may be more of a blessing than an overlooked bit of regulation by the Feds. Without specific guidance, the FAA isn’t going to be telling you precisely what you need to carry to protect yourself from a fire, which means the average pilot should be able to afford at least a minimal amount of protection, even in rental aircraft.
Does this mean the FAA doesn’t care about in-flight fire-fighting equipment? Not at all. The freedom to choose under Part 91 does not extend into the enhanced safety regulations of Part 135 or Part 121 air carrier operations. The FAA long ago established guidance for hand-held fire extinguishers, which our safety-conscious pilot would do well to follow. From a safety standpoint, carrying anything less than the equipment required by the FAA for Part 135 operators is doing a disservice to yourself and your passengers. It is for this reason we’ll turn our attention to Advisory Circular (AC) 20-42C, Hand Held Fire Extinguishers for Use in Aircraft, and dispense with any discussion of non-Part 135 requirements and use only air carrier guidance on the care and feeding of hand-held fire extinguishers aboard the aircraft.
Where to find it: regulatory guidance
Essentially, the FAA has wisely delegated the hand-held fire extinguisher issue to agencies well qualified to determine the fitness of an extinguisher to fight a fire. In accordance with FAR 21.305 (d), the Administrator is allowed and has determined fire extinguishers may be considered FAA-approved through their acceptance by any of the following three agencies: the U.S. Coast Guard (USCG), Underwriter’s Laboratories (UL), or Factory Mutual Research Corporation (FMRC). The reader may be familiar with the first two, the third is more of an insurance industry qualifying group. Two things are important to note regarding this: the AC was written in 1984 and the USCG no longer performs its own approvals of fire extinguishers — USCG approval is now accomplished by UL or UL Canada.
I spoke with the FAA Flight Standards office in Washington, D.C., as well as an instructor at the FAA Academy in Oklahoma City and both agree the only guidance the FAA provides the aviator is through AC 20-42C (with the relevant FARs cited in the AC). The representatives also were clear the fire extinguisher does not need to be FAA approved in any way. It doesn’t need a yellow tag from an A&P nor does it need an FAA form 8130. If you’re a Part 135 operator, your extinguisher needs to be approved by the agencies cited above, but beyond that you don’t need any extraordinary documentation.
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