Oxygen - use of Aerox portable or built-in kit

Guest Discussion
#1

I just got off the phone with http://www.aerox.comAreox, regarding use of their portable systems in the Cirrus and incorporation of their built-in kits. According to Aerox, you can use their portables in the Cirrus. (Why am I not surprised they’d say that?) According to them, just because the Mountain High unit is approved doesn’t mean that others are precluded. He said he heard the reason the Feds wanted the tank in the front seat instead of the seat back was their concern that the rear seat passenger might whack their head on the tank if it was placed on the back of the front seat. Pilot access to the valves was probably also a consideration.

They are interested in pursuing an STC for incorporation of their built-in kit in the Cirrus. He gave me the name of an outfit in California that does a lot of the kit installations (with 337s): Lake Aero Styling, Lakeport, CA (707) 263-0452.

My interest in the Aerox system is based on my current use of their portable system, which I have found to be of the highest quality and comfort, and the fact that oxygen consumption using their Oxysaver cannulas is very low.

Gordon

#2

I’ve been using the Aerox portable system since getting my SR20. The certification issue is an interesting one, as I really doubt that there is any regulatory issue with carrying a portable system, which after all is not “installed” in the aircraft and is not subject to STC or 337. As long as it is properly secured, it probably doesn’t run afoul of hazmat regulations and ought not to hurt anyone.

By the way, the Aerox (and probably the Mountain High) can be attached to one of the back seats, since they are handily split so that the straps can be passed around (and under the back.) I’ve found that installing, er, securing the system on the right back seat provides for accessibility and visibility to the pilot while not taking up the front seat. Occasional monitoring with a pulse oxymeter completes the picture.

#3

According to them, just because the Mountain High unit is approved doesn’t mean that others are precluded.
Gordon,
I agree that this restriction on Oxygen system brand seems a little ridiculous; but I think that Aerox’s comment (above) is miguided. My understanding of the FARs is that pilots are required to follow every stipulation of the Official FAA Approved Airplane Flight Manual (our P.O.H.), which says:
*Whenever the operating rules require the use of supplemental oxygen, the pilot must:

  • Use an oxygen system approved by Cirrus Design and listed in the Oxygen System AFM Supplement Part Number 11934-S09.
  • Secure the oxygen bottle in the right front seat as described in the AFM supplement noted above.*

I’m not a lawyer, but it seems to me that the Aerox claim is probably not true from a strictly legal point of view. Some time ago, I discussed this with someone at CD, who said “Yes, but what are the chances of the FAA stopping you on the ramp and complaining about which Oxygen system you’re using?” - which is, I suppose, a valid point - at least until it happens to me.

I don’t have the Oxygen System AFM Supplement here, so I don’t know if it contains anything that could change this… like maybe only recommending the Mountain High system as opposed to specifying it. Perhaps someone who has it handy could comment?

  • Mike.
#4

I own the Aerox portable system and use it in my A36. When I get my SR20 - N345MR - I plan to use the Aerox system in the SR20. POH sounds like an attorney doing CYA work for Cirrus. I never fly above 12,500 feet - therefore I never operate where O2 is required.

#5

I just spoke with the technical issues section of the AOPA. Paul in very clear language said “they (Cirrus) can not require the use of an oxygen system. They cannot require where the system is installed. Under part 91 pilots are not required to follow the POH. You can use whatever portable system you want and in can locate it where ever you want.”

This is a very clear statement that the (refering to the SR22 POH) POH section 2 limitation for Oxygen System and the Section 9 Supplements for Approved Oxygen Systems are NOT MANDATORY for me and most likely for all of you.

Have a great weekend and drink in any and all oxygen you want – while enjoying your Cirrus.

Bob

#6

For what its worth, I had great luck with the tiny portable oxygen canisters that I got from Aeromedix, although I just checked on their web site and they no longer sell it.

The system consists of very small canisters that hold 8 minutes of oxygen for continuous use. They are wonderful for use with a pulse oximeter, where you can give yourself a hit whenever your oxygen level drops too low.

(course, this is only for use below 12.5K, which is fine for us SR20 owners)

-Brand

#7

Why don’t you guys worry about an O2 system for the engine first and then an O2 system for the pilot because without one for the engine there really isn’t need for one for the pilot. I have had the sr20 at 13500 and the performance sucked. I spent the last two days in an sr20 at 10500 and it was still a little weak but I was fine. If you feel so out of it that you have to use O2 in an sr20 maybe you should try a couple laps around the track. It’s the best portable O2 system I know!

I’ve been using the Aerox portable system since getting my SR20. The certification issue is an interesting one, as I really doubt that there is any regulatory issue with carrying a portable system, which after all is not “installed” in the aircraft and is not subject to STC or 337. As long as it is properly secured, it probably doesn’t run afoul of hazmat regulations and ought not to hurt anyone.

By the way, the Aerox (and probably the Mountain High) can be attached to one of the back seats, since they are handily split so that the straps can be passed around (and under the back.) I’ve found that installing, er, securing the system on the right back seat provides for accessibility and visibility to the pilot while not taking up the front seat. Occasional monitoring with a pulse oxymeter completes the picture.

#8

Who gives a crap about how YOU feel at 10,500?

Why don’t you guys worry about an O2 system for the engine first and then an O2 system for the pilot because without one for the engine there really isn’t need for one for the pilot. I have had the sr20 at 13500 and the performance sucked. I spent the last two days in an sr20 at 10500 and it was still a little weak but I was fine. If you feel so out of it that you have to use O2 in an sr20 maybe you should try a couple laps around the track. It’s the best portable O2 system I know!

I’ve been using the Aerox portable system since getting my SR20. The certification issue is an interesting one, as I really doubt that there is any regulatory issue with carrying a portable system, which after all is not “installed” in the aircraft and is not subject to STC or 337. As long as it is properly secured, it probably doesn’t run afoul of hazmat regulations and ought not to hurt anyone.

By the way, the Aerox (and probably the Mountain High) can be attached to one of the back seats, since they are handily split so that the straps can be passed around (and under the back.) I’ve found that installing, er, securing the system on the right back seat provides for accessibility and visibility to the pilot while not taking up the front seat. Occasional monitoring with a pulse oxymeter completes the picture.

#9

  1. Some of us have SR22’s, which have excellent performance up to 18,000’.

  2. Some people feel terrible at lower altitudes. It has little to do with conditioning and seems to be mostly due to the “luck of the draw” in one’s physiology. E.g., I have climbed peaks over 21,000’ in Asia with no supplemental O2 and with little trouble (other than the obvious that I was short of breath) while my wife starts getting uncomfortable symptoms above 6,000’. I have some papers on high altitude physiology if anyone is interested.

I should add that of course one’s ability to do work at altitude has a lot to do with conditioning.

  1. Random data point: I have read that the US Navy requires its pilots to use O2 when above 5,000’ at night. Lack of O2, even at such low altitudes, reduce’s one’s night vision.

  2. Posting anonymously is curious in this case. Why not include your name? You’re not blowing the whistle on anyone, what do you have to lose?

Why don’t you guys worry about an O2 system for the engine first and then an O2 system for the pilot because without one for the engine there really isn’t need for one for the pilot. I have had the sr20 at 13500 and the performance sucked. I spent the last two days in an sr20 at 10500 and it was still a little weak but I was fine. If you feel so out of it that you have to use O2 in an sr20 maybe you should try a couple laps around the track. It’s the best portable O2 system I know!

I’ve been using the Aerox portable system since getting my SR20. The certification issue is an interesting one, as I really doubt that there is any regulatory issue with carrying a portable system, which after all is not “installed” in the aircraft and is not subject to STC or 337. As long as it is properly secured, it probably doesn’t run afoul of hazmat regulations and ought not to hurt anyone.

By the way, the Aerox (and probably the Mountain High) can be attached to one of the back seats, since they are handily split so that the straps can be passed around (and under the back.) I’ve found that installing, er, securing the system on the right back seat provides for accessibility and visibility to the pilot while not taking up the front seat. Occasional monitoring with a pulse oxymeter completes the picture.

#10

Well, look at the book #s for the SR22, which, had you looked at my post, you would have realized we’re talking about. The airplane is quite robust up into the teens, can get there very quickly, is just as fast on less fuel, and, for those of us who live in areas of the country populated by majestic mountains instead of flatlands, or who prefer to fly above weather and turbulence and sometimes ice, you bet it makes a difference.

G

Why don’t you guys worry about an O2 system for the engine first and then an O2 system for the pilot because without one for the engine there really isn’t need for one for the pilot. I have had the sr20 at 13500 and the performance sucked. I spent the last two days in an sr20 at 10500 and it was still a little weak but I was fine. If you feel so out of it that you have to use O2 in an sr20 maybe you should try a couple laps around the track. It’s the best portable O2 system I know!

I’ve been using the Aerox portable system since getting my SR20. The certification issue is an interesting one, as I really doubt that there is any regulatory issue with carrying a portable system, which after all is not “installed” in the aircraft and is not subject to STC or 337. As long as it is properly secured, it probably doesn’t run afoul of hazmat regulations and ought not to hurt anyone.

By the way, the Aerox (and probably the Mountain High) can be attached to one of the back seats, since they are handily split so that the straps can be passed around (and under the back.) I’ve found that installing, er, securing the system on the right back seat provides for accessibility and visibility to the pilot while not taking up the front seat. Occasional monitoring with a pulse oxymeter completes the picture.

#11

Mike:
Your point is well taken. I did not have the POH with me this morning when I posted my statement, and certainly the chapter and verse you quoted casts it in a different light.
Don’t blame the Aerox guy, though. He was stating an opinion without knowledge of the POH verbiage as well. I think he was probably speaking from past experience regarding use in other aircraft.
He did state that he would definitely be interested in pursuing an STC for the Cirrus for their built-in kits, and even stated that he’d consider covering the cost of the regulatory aspects of any effort I made should I go for a 337. He knows that a significant market will exist, and I’d recommend that any SR2x owner that is interested in pursuing a built-in solution contact him to see if a joint effort can benefit both parties and future O2-starved blue-nailed Cirrus owners. His name is Lloyd Boston, and Aerox is at 1-800-237-6902 (East coast).
I started using O2 any time I’m going to be at 8000+ for any length of time, and the occasional mild headaches I used to have after a x-county flight are no more.
Gordon

According to them, just because the Mountain High unit is approved doesn’t mean that others are precluded.

Gordon,

I agree that this restriction on Oxygen system brand seems a little ridiculous; but I think that Aerox’s comment (above) is miguided. My understanding of the FARs is that pilots are required to follow every stipulation of the Official FAA Approved Airplane Flight Manual (our P.O.H.), which says:

*Whenever the operating rules require the use of supplemental oxygen, the pilot must:

  • Use an oxygen system approved by Cirrus Design and listed in the Oxygen System AFM Supplement Part Number 11934-S09.

  • Secure the oxygen bottle in the right front seat as described in the AFM supplement noted above.*

I’m not a lawyer, but it seems to me that the Aerox claim is probably not true from a strictly legal point of view. Some time ago, I discussed this with someone at CD, who said “Yes, but what are the chances of the FAA stopping you on the ramp and complaining about which Oxygen system you’re using?” - which is, I suppose, a valid point - at least until it happens to me.

I don’t have the Oxygen System AFM Supplement here, so I don’t know if it contains anything that could change this… like maybe only recommending the Mountain High system as opposed to specifying it. Perhaps someone who has it handy could comment?

  • Mike.
#12

I started using O2 any time I’m going to be at 8000+ for any length of time, and the occasional mild headaches I used to have after a x-county flight are no more.
Hi Gordon,
Yes… my comments weren’t meant as a criticism of either Aerox or the guy you spoke with.
Actually, even according to the POH, at 8,000 feet you can probably use anything you want (again, my understanding!) - because of the wording which says Whenever the operating rules require the use of supplemental oxygen…, and below 12,500 feet the rules don’t require its use (usual caviat - my understanding). So, if I’m ramp-checked, I can always say that I have no intention of flying where Oxygen is required, only where it’s desired; provided, of course, that the ramp-check is before my flight!

:slight_smile:

  • Mike.
#13

Actually, even according to the POH, at 8,000 feet you can probably use anything you want (again, my understanding!) - because of the wording which says Whenever the operating rules require the use of supplemental oxygen…, and below 12,500 feet the rules don’t require its use (usual caviat - my understanding). So, if I’m ramp-checked, I can always say that I have no intention of flying where Oxygen is required, only where it’s desired; provided, of course, that the ramp-check is before my flight!

#14

Actually, even according to the POH, at 8,000 feet you can probably use anything you want (again, my understanding!) - because of the wording which says Whenever the operating rules require the use of supplemental oxygen…, and below 12,500 feet the rules don’t require its use (usual caviat - my understanding). So, if I’m ramp-checked, I can always say that I have no intention of flying where Oxygen is required, only where it’s desired; provided, of course, that the ramp-check is before my flight!

I was told that because the POH gives specific requirements for O2 system and mounting requirements (front seat) the use of anything else even below 12500 is not legal. As for the chance of getting caught, once the FAA realizes that they can find violations by checking the O2 systems in an SR2x, I would not bet my certificate on them not doing it just to improve their enforcement score.

#15

So, if I’m ramp-checked, I can always say that I have no intention of flying where Oxygen is required, only where it’s desired; provided, of course, that the ramp-check is before my flight!

I was told that because the POH gives specific requirements for the O2 system (Mountain High) and mounting requirements (front seat) the use of anything else even below 12500 is not legal. As for the chance of getting caught, once the FAA realizes that they can find easy violations by checking the O2 systems in an SR2x, I would not bet my certificate on them not doing it just to improve their enforcement score.

Sorry about the multiple posts.

#16

My best suggestion is to write to your local FAA and tell them that you have system “X” and you want to place it in “…” (back seat or bagage area and you want them to say that this is ok.
If the worst happens. You have something from the authority (local FAA) that says …
Remember that we live in a free country, what works for the local FAA may not work for the other FAA that is only a state away. Best location is under the seat for the bottle. Try to take an evasive action (a quick turn + up or down) and watch the bottle as it is now a missile because it was loose and broke the valve off. It must be secured. If you have a good system you can turn in on fly for two hours and if you did not use it you should not have lost any pressure. Turn it on (under the seat) during your interior check prior to your exterior preflight. Have a great Cirrus day at Flight Level 240
Woor

Actually, even according to the POH, at 8,000 feet you can probably use anything you want (again, my understanding!) - because of the wording which says Whenever the operating rules require the use of supplemental oxygen…, and below 12,500 feet the rules don’t require its use (usual caviat - my understanding). So, if I’m ramp-checked, I can always say that I have no intention of flying where Oxygen is required, only where it’s desired; provided, of course, that the ramp-check is before my flight!

#17

Art - who told you this?

I was told that because the POH gives specific requirements for the O2 system (Mountain High) and mounting requirements (front seat) the use of anything else even below 12500 is not legal. As for the chance of getting caught, once the FAA realizes that they can find easy violations by checking the O2 systems in an SR2x, I would not bet my certificate on them not doing it just to improve their enforcement score.

Sorry about the multiple posts.

#18

Another Mike R! Now we got N345MR AND N84MR! Clyde, do something! I hope to see N84MR at the ECCFI Sat; can’t wait to see all the gadgets!

Mick-NC

#19

Under part 91 pilots are not required to follow the POH.
Bob,
I hate the volume and complexity of the FARs as much as anyone I know (maybe more), but this didn’t sound right to me, so I looked it up.
§ 91.9 Civil aircraft flight manual,
marking, and placard requirements.
(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.

Paragraph (d) has to do with helicopter operations.

Am I missing something, or is the news still bad?

  • Mike.
#20

Mike

I have no interest in knowing the FARs on this subject. Therefore, I went to the experts, I only know what I have been told.

I will follow the AOPA advice I received until an authorative source for another interpertation is found. Something like sticking my head in the clouds.

Bob