AVIATION REQUIREMENTS FOR FIRE EXTINGUISHERS
1 What are the legal requirements concerning aviation fire extinguishers?
The FAA does not provide a list of authorized fire extinguishers for aircraft. The FAA does specify the following regulations. According to AC 20-42C, “Hand Fire Extinguishers for Use in Aircraft, which provides methods acceptable to the Administrator for showing compliance with the hand fire extinguisher provisions in Parts 25, 29, 91, 121, 125, 127, and 135 of the FAR.”
“The FAA accepts hand fire extinguishers approved by Underwriters Laboratories, Inc.”
“For occupied spaces on aircraft, Halon 1211 extinguishers should not be less than 2½ pounds (1.2kg) capacity. These extinguishers should have a minimum 5B:C rating; not less than 8 seconds effective discharge time; not less than a 10 ft. (3 meter) range, and may be equipped with a discharge hose.”
“Halon fire extinguishing agents approved for use include …a combination of the two (Halon 1211 and Halon 1301).”
“Halon 1211 is a multipurpose, Class A, B, C rated agent effective against flammable liquid fires. Halon 1301 offers limited Class A capability when used in portable fire extinguishers.”
“In accordance with Section 21.305(d) of the FAR, the FAA accepts handheld extinguishers approved by Underwriters Laboratories…” Also, in accordance with Section 25.851 (601(b1) “An approved type fire extinguisher includes those approved by the Underwriter’s Laboratories, Inc., Factory Mutual, Underwriter’s Laboratories of Canada…”
“Non-refillable disposable fire extinguishers (1211-1301) are exempt from the periodic hydrostatic test requirements.”
2 Is Halon still legal for aviation use?
As of April 6, 1998, the manufacture of the Halon 1211-1301 blend has been prohibited (Federal Register, 63 FR 11084 dated March 5, 1998) except for aviation fire protection, provided that the owner at the time of disposal, if there is any Halon remaining in the unit, returns the extinguisher to the manufacturer for the recycling of the Halon.
Therefore, effective April 6, 1998, the Halon 1211-1301 blend has been sold exclusively to aviation users.
The rule does not prohibit:
The sale or use of Halon blends produced prior to April 6, 1998.
Halon 1211 propelled by nitrogen.
Halon 1211-1301 blend sold outside of the United States.
3 Can I use a dry chemical fire extinguisher rather than Halon?
The best way to answer this question is to cite NFPA Standards and other published documents:
NFPA 410 Aircraft Maintenance (Addendum) A-7-3.1
All-purpose (ABC) dry chemical-type extinguishers should not be used in situations where aluminum corrosion is a problem.
NFPA Fire Protection Handbook Chapter-Basics of Fire and Science
Extinguishment with Dry Chemical Agents:
One reason that dry chemical agents other than monoammonium phosphate are popular has to do with corrosion. Any chemical powder can produce some degree of corrosion or other damage, but monoammonium phosphate is acidic and corrodes more readily than other dry chemicals, which are neutral or mildly alkaline. Furthermore, corrosion by other dry chemicals is stopped by moderately dry atmosphere, while phosphoric acid has such a strong affinity for water that an exceedingly dry atmosphere would be needed to stop corrosion.
Air Transport Newsletter, by Ronald Horn, Nov./Dec. 1983, “Class A-B-C Extinguishers Damage Aircraft”
“The A-B-C extinguishers have excellent fire-fighting capability, but the mono-ammonium-phosphate chemical agent melts and flows when it comes into contact with heat. This is how it gets its Class A rating. This chemical is highly corrosive to aluminum, and once it contacts hot aluminum and flows down into the structural cracks and crevices it cannot be washed out as the B-C dry chemical agents can.
“Once an A-B-C extinguisher is used on an airplane, it is necessary to disassemble the aircraft piece by piece and rivet by rivet to accomplish cleanup. Failure to do so will result in destruction of the aircraft by corrosion.”
4 Does the FAA require a “gauged” extinguisher?
A fax received from the FAA along with excerpts from AC 20-42C and 25.851 clearly indicate that a gauge is not a requirement on any type of aircraft. The fax response states: “There should be no problem with an extinguisher that is UL-approved and has no gauge for extinguishing capacity, provided that the weight tolerance for the extinguishant is known.”
5 Do I need an FAA form 8130-3 for this fire extinguisher?
No, not in North America. A factory-new Halon fire extinguisher does not require an 8130-3 because it is not considered an aircraft part.
The FAA does not provide a list of authorized fire extinguishers for aircraft. The FAA does specify the following regulations. According to AC 20-42C, “Hand Fire Extinguishers for Use in Aircraft:”
“The FAA accepts hand fire extinguishers approved by Underwriters Laboratories, Inc.
“For occupied spaces on aircraft, Halon 1211 extinguishers should not be less than 2½ pounds (1.2kg) capacity. These extinguishers should have a minimum 5B:C rating; not less than 8 seconds effective discharge time; not less than a 10 ft. (3 meter) range, and may be equipped with a discharge hose.”
6 Do regulations require that a Halon fire extinguisher be removed from a plane at high temperatures?
Following are excerpts from three key documents regarding the use of fire extinguishers on aircraft.
In AC20-42C, “Hand Held Fire Extinguishers for use in Aircraft,” the FAA recommends “approved” (such as by UL) fire extinguishers for use in aircraft, but mentions nothing about removing a fire extinguisher from an aircraft due to temperature.
NFPA 408, 2-1.4, “Standard for Aircraft Hand Portable Fire Extinguishers,” states: “All aircraft hand portable fire extinguishers shall function properly at temperature ranges from -40 degrees F to 120 degrees F.”
NFPA 10 “Standard for Portable Fire Extinguishers” does call for aluminum-shelled fire extinguishers to be removed from service and hydrostatically tested if they are exposed to temperatures in excess of 350 degrees F.
