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Ferry tank discussion (merged)

No, we ran the fuel first through a fuel filter which took out contamination/dirt and water from the supplied fuel as seen in the below picture. This picture was by the way taken at Juba airport in South-Sudan. We bought the remaining AVGAS that MAF had there, but the airport and city were surrounded by rebels making war. I think a tank was pointed at us at the end of the runway to make sure we were friends.

The tank protecting the runway and checking incoming traffic :-)

Last Edited by AeroPlus at 26 Aug 16:26
EDLE, Netherlands

AeroPlus wrote:

I must say that this fuel solution was essential. I gave a slideshow presentatation of my trip at a PPLIR meeting and some CAA officials seemed to be in the room. It did not really seem to bother them at all.

In places like Africa, you just have to be practical. From a practical point of view I will add a picture of how on a big major airport the handler guys approach you on the airport to refuel. It says enough I think.

I just wish both the FAA and the EASA people would take the practically minded approach to aviation, instead of conjuring up ways to protect aviation from aviation.

KHTO, LHTL

C210_Flyer wrote:

I just wish both the FAA and the EASA people would take the practically minded approach to aviation

FYI, the carriage of fuel in the cabin is not legal in Africa either ( at least in the places I know), but is quite often simply a necessity….

There is another set of regulations only mentioned briefly in this thread. They are the UN packaging regulations. If your ferry tank is plumbed into the aircraft the whole set up must be approved, we all know that. However, it seems to have been claimed here that because the tank, flexible tank or jerry cans is not connected permanently into the fuel system then it’s just cargo.

Wrong. The UN packaging regulations kick in here (Avgas and Jet A1 are both classed as hazardous substances) for up to 2000 litres (grey area and could be up to 3000 litres dependant upon product) because it’s now cargo. Furthermore, the UN approval is not sufficient alone, because the package is being carried in an aircraft the package has to be IATA approved as well. So, if the ferry tank is just “cargo” make sure it has the packaging approvals and is in test and an IATA approval. I can tell you that it’s highly unlikely either of these approvals will exist and I’d be astonished if a refueller has any clue to these requirements so any old Jerry Can or tank will be filled without enquiry. You can bet your insurer will know about it and would use it against you. This is a hugely complex area, my business rents out containers so we have a lot of experience in the area of packaging and transportation of all sorts of liquids including hazardous products like Avgas/Jet A1.

We came across the IATA issue with an Australian contract we had shipping Avgas in 1000 litre Stainless Steel containers from Darwin to Bathurst Island on a barge. The ship has to comply with the IMO regulations, the UN approval (Class II) covered us for transportation on the barge. However, once on the island they wanted to ferry tanks singly to remote airstrips. Their insurers asked for the UN certification and IATA certification. We only had UN so the containers could not be used in an aircraft.

I’m not sufficiently acquainted with the IATA approval to know it well. There may be a lower capacity limit (20 litres say) where the UN approval will suffice even in an aircraft. I know a ferry pilot who regularly carries 20 litre UN approved plastic containers on trans-Atlantic crossings. I have two of them here and they are only UN and not IATA???

One thing is for sure, the Turtle tanks mentioned here, if not under and STC or similar and plumbed into the aircraft fuel system then it’s cargo and all these other package approvals kick in and as they are reusable packages they will require a re-test under UN every two years, not sure about IATA.

Sorry to rattle on, this whole are is highly complex as it said earlier.

EGNS/Garey Airstrip, Isle of Man

STOLman wrote:

The UN packaging regulations kick in here (Avgas and Jet A1 are both classed as hazardous substances) for up to 2000 litres (grey area and could be up to 3000 litres dependant upon product) because it’s now cargo. Furthermore, the UN approval is not sufficient alone, because the package is being carried in an aircraft the package has to be IATA approved as well.

Neither UN nor IATA have lawmaking power so those regulations are irrelevant unless they are somehow mirrored in local law (EU or country law).

So if the regulations are irrelevant why are they there? As far as I know they are applied worldwide. Of course if you want to take the risk then that’s up to the individual.

EGNS/Garey Airstrip, Isle of Man

The brass band of Ditchweed municipal high school in Iowa also has its set of regulations but they don’t apply to me. Neither do IATA nor UN rules unless they are also found in law. I don’t rule out the possibility but pointing to IATA or UN rules is not helpful because they are not sources of applicable law. As private aviators we are not IATA members. The UN packaging regulations are used by commercial cargo companies.

Ask your insurance company.

EGNS/Garey Airstrip, Isle of Man

IATA do not apply to private flights unless certain elements of IATA’s rulebook have found entrance in local law. However, it happens that insurances or also national authorities look at IATA for certain rules and either make them national law or at least refer to them in case of legal hassles. For instance, IATA standard passenger weights or also cargo rules, in particular hazmat rules, are often either completely taken over or at least consulted when it comes to judging accidents or incidents. And insurances may refer to them in their conditions or in case of a dispute. So STOLman has a very valid point, even if they are not direct law, they are anything but insignificant.

ICAO however is valid wordwide and the underlying rulework for the local rules. Both FAA and EASA rulemaking bases on ICAO. You may therefore safely assume that national law is alwas more restrictive than ICAO. if ICAO specifies those rules, they will, probably more restrictive, be applicable to all airplanes worldwide, irrespective of where they are registered as the national air law has to correspond to ICAO.

Looking at sites like Worldrounders and others I wonder what the issue is. Turtlepacks and other ferry tanks get used there a lot and usually the approval for them is not a very extreme issue. So I kind of fail to see why not seek approval for something you regularly use rather than relying on non-applicability of international law?

LSZH(work) LSZF (GA base), Switzerland

achimha wrote:

Neither do IATA nor UN rules unless they are also found in law.

Unfortunately they do – in EU regulation 965/2012 (the one with operations regulations, part-CAT, part-NCO etc.). Article V states that operators should comply with Annex V when transporting dangerous goods. No distinction is made between commercial and noncommercial operations.

Annex V includes subpart G (SPA.DGO) which states that you need approval and that you have to follow the “technical instructions”. Annex I (definitions) defines the “technical instructions” to mean the ICAO “Technical Instructions For The Safe Transport of Dangerous Goods by Air”.

As far as I can make out after some quick googling, the ICAO Technical Instructions mirror the UN recommendations mentioned earlier. The IATA “Dangerous Goods Regulations” reproduces the ICAO Technical Instructions and additionally provides application guidelines.

ESKC (Uppsala/Sundbro), Sweden
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