Official comments to the proposed consultation paper are to be filed through the EASA Comment-Response Tool (CRT).
Details
Identification of issue
The purpose of this Certification Memorandum is to provide guidance on the certification of the installation of Halon-free handheld fire extinguishers on CS-23, CS-25, CS-27 and CS-29 aircraft.
Regulation (EC) No 2037/2000 of the European Parliament and of the Council of 29 June 2000 on substances that deplete the ozone layer, contains initial provisions for Halon phase-out, but also exemptions for critical uses of Halon, including fire-extinguishing in aviation. The exemptions were predicated on the basis that there were, at that time, no suitable alternate agents or systems available for use on aircraft.
‘Cut-off’ dates (i.e. Halon no longer acceptable in new applications for type certification) and ‘end’ dates (i.e. Halon no longer acceptable for use in aircraft) were established by European Commission Regulation (EU) No 744/2010 of 18 August 2010.
The end date is defined as the date by which all Halon-based handheld extinguishers must be decommissioned.
Consequently, EASA has amended CS-23, CS-25 and CS-29 to provide guidance on how to address the requirements of the above European Commission Regulations when certifying the installation of handheld fire extinguishers, and more in general, of fire protection systems using Halon-free extinguishing agent.
Historically Halon 1211 has been the most widespread agent in handheld (portable) fire extinguishers to be used in aircraft compartments and cabins. Minimum Performance Standards (MPS) for the agents are laid down in Appendix A to Report DOT/FAA/AR-01/37 of August 2002, while acceptable criteria to select the fire extinguishers containing said agents are laid down in the FAA Advisory Circular AC 20-42D.
While CS-27 does not explicitly require the installation of handheld fire extinguishers, FAA AC 27.853 (referenced in AMC 27 General) clarifies that, if a handheld fire extinguisher is installed to comply with an operating rule, the guidance of FAA AC 20-42D should be followed. Furthermore, handheld fire extinguishers have been installed on CS-27 rotorcraft to enhance safety features, even if not required by the applicable aircraft certification basis.
The relevant AMCs of CS-23, CS-25 and CS-29 clarify that in case an applicant wishes to propose any alternative agent for hand fire extinguishers meeting the mentioned MPS, particular coordination with the Agency would be needed.