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EASA approves a pragmatic solution to the fire extinguisher issue

You may recall previous articles on this topic: The EU has banned halon-containing fire extinguishers in aircraft cabins for environmental reasons. What does this mean for general aviation? Non-commercial aircraft under 1200 kg are exempt from the requirement to carry fire extinguishers. However, aircraft over 1200 kg MTOM are required to carry a fire extinguisher, even in non-commercial operation. The legal basis for this is NCO.IDE.A.160. Currently, halon-free extinguishers with aviation approval are scarce, as airlines are currently buying up all available stock and are themselves retrofitting their aircraft. Aviation-certified fire extinguishers with the permitted successor substance "Halotron 2" are also very expensive, costing around €1500 for the smallest available size.

But above all, aviation-approved fire extinguishers create a completely different problem for the occupants of confined cabins: Their use poses a serious health risk, as the extinguishing agents severely irritate the respiratory system. Typically, the smallest fire extinguishers are approved for cabin sizes starting at around 10 m³, but a four-seater aircraft only has a cabin volume of approximately 2 m³. A fire extinguisher empties in about 10 seconds. Therefore, after a spray lasting just 2 seconds, the health risk threshold for aircraft occupants is already reached.
So, in the event of a fire, are we supposed to choose between burning to death or suffocating, or are there other solutions that are ideally not only safe but also cost-effective?
Yes, there are. It's quite obvious that there are also inexpensive, compact fire extinguishers weighing around 500g and costing under €100. These are specifically designed for use in small spaces like kitchens, cars, and sports boats. They use harmless aerosols and therefore, even when used in the cockpit, do not endanger the occupants or even the avionics. What more could you want?
The European IAOPA has recommended to EASA that aircraft operators be officially allowed to choose suitable fire extinguishers themselves.
It took some time, but it has now been successful. The EASA experts apparently find our argument convincing and have adopted it. Only equipment that is permanently installed must be approved for aviation according to NCO.IDE.A.100 (4).


What should you, as an aircraft owner, do now?

  • Look for suitable fire extinguishers that extinguish a fire without endangering the occupants. We found two aerosol fire extinguishers on the market: the eJet Aerosol (approx. €60) and the Maus XTIN Klein (approx. €100), which you can easily find with an internet search.
  • The fire extinguishers should be stored in the cabin in a way that allows easy access, but they shouldn't be unsecured when in use: for example, in the glove compartment, side pockets, etc., but not permanently attached to the aircraft.
  • It's also a good idea to consider a fireproof bag and a glove for tablet computers or mobile phones, which, statistically speaking, have the highest probability of catching fire and which cannot usually be extinguished with a fire extinguisher. These are available online for around €20.

This solution does not help operators of aircraft in commercial (Part NCC) and company transport (Part NCC), as certified fire extinguishers are mandatory in these cases.


However, there is still room for discussion: If the aircraft is type certificated with a permanently installed fire extinguisher according to CS23 and the aircraft's type approval, then the solution outlined above for non-permanently installed and non-aviation-approved equipment does not apply according to EASA interpretations. We believe, however, that according to OPS NCO.IDE.A.100 (b)(5), safety equipment such as emergency axes, first-aid kits, etc., do not require approval, and that the same should then apply to fire extinguishers that are easily removable and just mounted in a fixed installed bracket.

An official communication from EASA will be issued in the coming weeks.

February issue of the UK AOPA Magazine is out

 

 

 

 

Download as a PDF for offline reading

 

For older editions of the UK AOPA Magazine please visit the archive

Overview of member benefits

With a growing list of member benefits we have now compiled a list of member benefits available to members of affiliates of IAOPA Europe.

The lists has been constantly growing with partners such as Jeppesen, TopMeteo & Safesky.

The latest addition is Foreflight where a 25 percent discount is now available.

Please check the list at www.iaopa.eu/memberbenefits

We will update the list regularly as new benefits are added

Cost-Sharing flights under renewed scrutiny across Europe

Recent developments in several European countries highlight the growing focus on cost-sharing flights — and the need for clarity in how rules are applied.

In Finland, a case is developing where the national CAA claims a pilot operating cost-sharing flights is effectively running a commercial operation because the aircraft is privately owned.

The UK has recently tightened its approach following the high-profile Sala accident, which involved an illegal charter flight. Starting in October, UK pilots conducting cost-sharing flights must ensure passengers pay an equal share of the cost. Passengers are also required to fill out a participation form, which the pilot must keep for six months — allowing investigators to confirm compliance if necessary. According to AOPA UK’s Martin Robinson, these changes are intended to make enforcement easier but will likely have limited impact on illegal charter flights due to limited oversight resources.

In Denmark, a case was previously taken to court by the CAA seeking to convict a pilot for not paying an equal share of the costs on a cost-sharing flight. The court dismissed the case, ruling correctly that EU regulations only require the pilot to pay a share, not necessarily an equal one. This ruling reinforces the principle that cost-sharing flights remain a legal way for private pilots to defray operating costs, provided they do not turn into disguised commercial operations.

One of the open questions that still causes confusion and uncertainty is what can be considered ‘direct costs’ eligible for sharing and here the discussion centers on costs for items like insurance, maintanance and hangar. If a pilot rents an aircraft the entire rent is obviously a direct cost even if part of the rent is set obviously covering these elements. If the pilot owns the aircraft himself it does not seem logical that the same elements could not be taken into account when calculating 'direct costs'. This question remains open and could have wide-reaching implications for GA pilots across Europe.

IAOPA Europe is monitoring these developments closely, as several CAAs may look to replicate the UK model or even pressure EASA to revise its rules. ‘This is another example of regulators trying to solve a problem that may not really exist — while creating new burdens for legitimate GA activity,’ Martin Robinson noted.

What is a cost-sharing flight?

Under EU Regulation (EU) No 965/2012 (Part-NCO), private pilots may share the direct costs of a flight with up to five passengers, provided the pilot also contributes to those costs. Direct costs typically include fuel, oil, landing fees, and — if applicable — aircraft rental fees. The flight must be genuinely non-commercial: the pilot cannot make a profit and cannot be ‘holding out’ by offering air transport as a service.
Cost-sharing is a vital way for private pilots to reduce flying expenses, maintain currency, and keep GA accessible. However, interpretation of what counts as ‘direct costs’ and how flights are advertised remains a point of discussion with regulators.