Flashlight

[topdawg]

I had a captain tell me I have to have a flashlight that requires 2 D- cell batteries. Where in the regs does it say this? 121.549 states that all you have to have is a flashlight in good working order. Can somebody please let me know. Thanks

 

[dondk]

all the reg's say.. it has to be 2 D cell or it's equivalent... (3 volts)...
Some read into the 2 D cell a bit too much.. Bottom line, as long as the flashlight has similar or greater power than 2 D cell's your good.. So, 2 C, 2 AA type mag's will not work, but 1- 3 volt zeon lamp flashlight using one of the lith-ion camera battery's works... A surefire or similar does the trick.

 

[Rick1128]

flash light

Be careful about that. The regs say that you have to have a flashlie that uses two D cells or equivilent. But they do not say you have to use it. Other flashlites are acceptable as long as you have a D cell with you. Further more when dealing with the Feds, they take it as face value. Since there are no lighting value standards, plan on having a flashlite with at least 2 D cells.

 

[TonyC]

all the reg's say.. it has to be 2 D cell or it's equivalent... (3 volts)...
Some read into the 2 D cell a bit too much.. Bottom line, as long as the flashlight has similar or greater power than 2 D cell's your good.. So, 2 C, 2 AA type mag's will not work, but 1- 3 volt zeon lamp flashlight using one of the lith-ion camera battery's works... A surefire or similar does the trick.

You seem to be pretty confident in your answer, knowing exactly what "equivalent" means - - 3 volts.


How many volts in a 2 C-cell flashlight? 3 volts

How many volts in a 2 AA-cell flashlight? 3 volts

How many volts in a 2 AAA-cell flashlight? 3 volts

If those don't serve as "equivalent", then "3 volts" must not be the definition of equivalent.

Perhaps it's candle power? If so, what's the basis for measurement? 2 fresh standard D-cells and a standard bulb? Same configuration after one hour of continuous use? Or is it fresh alkaline batteries and a Xeon bulb?

Is it voltage, or is it battery life? Is it lumens or candlepower? Maybe it's just size - - could a flashlight the size of a 2 D-cell batteries be adapted to use 6 AAA's and suffice?

Oh, the waters are not realy as clear as you might think. Every time you approach the bank, a little dirt falls off the side and muddies the issue.

 

[SkyWestCRJPilot]

Part 121.549 (b) says it only has to be in good working order.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=1f5e7d4882bf46bf87d7992684c6e301&rgn=div5&view=text&node=14:2.0.1.4.19&idno=14#14:2.0.1.4.19.20.11.14

Part 91.503 (a)(1) for Large and Turbine powered airplanes says it has to be 2 "D" cells or equivalent.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=1f5e7d4882bf46bf87d7992684c6e301&rgn=div5&view=text&node=14:2.0.1.3.10&idno=14#14:2.0.1.3.10.6.7.2

My understanding is that the reg under Part 121 used to say 2 "D" cells but was recently changed. I supposed if you are flying corporate though you still have to have a flashlight with 2 "D" cell batteries or equivalent.

 

[topdawg]

Skywestcrjpilot--Thanks for the references, after seeing those; as an SIC do I still have to have that equipment? Because 121.549 only states "flashlight in good working order" which I have (small AA but works good) and 91.503 says "The pilot in command of an airplane shall ensure that the following flying equipment and aeronautical charts and data, in current and appropriate form, are accessible for each flight at the pilot station of the airplane:

(1) A flashlight having at least two size “D” cells, or the equivalent, that is in good working order.

The way I understand it is technically I don't need 2 "D" cells... am i right?

 

[A Squared]

topdawg,

91.503 is in Subpart F, which is applicable to Large and turbojet multiengine aircraft. however, subpart 91 is not applicable if to these aircraft when they are required to be operated under Part 121, 125 129 135 or 137.

I assume, because you reference 121.549, that you are flying under Part 121. If that is the case than 91.503 is not applicable. So, you're only required to have "a flashlight"


If you were on a part 91 repostioning flight, 91.503 would apply, but in that case it, would be met by your captain having his flashlight. (he does have one, doesn't he?)

 

[Sol Rosenberg]

So what's the big deal. Why do some pilots not want to carry the required equipment? The regs say carry a 2d cell battery flashlight in working order, so why not do it? The regs say nothing about having to take the flashlight out and use it, so why not carry a small pen size light to use in the cockpit??

 

[TonyC]

So what's the big deal. Why do some pilots not want to carry the required equipment? The regs say carry a 2d cell battery flashlight in working order, so why not do it? The regs say nothing about having to take the flashlight out and use it, so why not carry a small pen size light to use in the cockpit??

It's not a matter of not wanting to carry the required equipment as much as it is a matter of not wanting to drag around extra weight. If a 2-AA flashlight can produce as effective a light source as a 2-D cell flashlight of the era when the reg was written, we'd prefer to carry the lighter weight version.

And, no, the regs don't say "carry a 2d cell battery flashlight in working order." The "or equivalent" is the subject of debate. Do you have an FAA-approved, legally tested, guaranteed to hold up in court definition of "equivalent" as it applies in this context?

Didn't think so. So, the only answer we can be ABSOLUTELY sure about is to carry a flashlight with 2 D cells. And, as you mentioned, why not carry a smaller light that is actually more useful - - your perogative, of course.


But, we're still pilots, and we'll put a great deal of thought and effort into making things easier. Yes, we work hard at being lazy. Oops, I think I've strayed into the "Pilot Stereotypes" thread.

 

[topdawg]

Geez this is getting confusing... So a simple answer to question would be that as an SIC flying under 121, I personally do not need a "D" cell flashlight. The PIC needs one only if the flight is flown under part 91. Is this correct?

 

[JAFI]

Below is the only legal interpitation I could find on the 121.549 "Flashlight " issue. The Short answer: the Equivalent to a two "D" cell flash light is " must be left to Flight Standards or the Engineering Division to determine."

( the below letter contains only the portion for the equivelent issue).
JAFI
____________________________-
April 10, 1992

AEA-7



This is in response to a request for assistance dated October 11, 1991, from Loretta E. Alkalay, Assistant Chief Counsel, Eastern Region, to Richard C. Beitel, Manager, Operations Law Branch, Regulations and Enforcement Division. The request involves the interpretation of Federal Aviation Regulations (FAR) Sec. 121.391(d), 121.549(b) and 91.503(a). For your convenience the applicable sections of the FAR are listed separately below followed by the specific questions and our interpretation.



Question:



Is there a policy letter regarding the interpretation of this regulation?



Answer:



AFS-200 furnished the attached letter dated August 18, 1976, written by R. L. Collie. You may ask AFS-200 whether it is considered a policy letter.



FAR Sec. 91.503(a): The pilot in command of an airplane shall ensure that the following equipment and aeronautical charts and data, in current and appropriate form, are accessible for each flight at the pilot station of the airplane:



(1) A flashlight having at least two size "D" cells, or the equivalent, that is in good working order.



Question:



What is the equivalent of 2 size "D" cells?



Answer:



The technical equivalent of 2 size "D" cell batteries must be left to Flight Standards or the Engineering Division to determine. A historical review of FAR Sec. 91.503(a)(1) indicates that the proposed language used in the Notice of Proposed Rulemaking (NPRM) 71-32, originally read "A flashlight in good working order." After receiving comments to NPRM 71-32, Sec. 91.183(a)(1), the predecessor to Sec. 91.503(a)(1), was changed to its present language to preclude the use of a penlight or other inadequate light as a substitute for the type of flashlight normally carried on an airplane for emergency use. Presumably, the drafters and some commenters of the regulation were concerned that the word "flashlight" alone was inadequate and that a flashlight used in an emergency situation should have equal light producing capability and should, as a minimum, meet certain intensity and endurance standards which should result in a light output similar to that provided by a flashlight having 2 size "D" cell batteries. The regulatory history, however, is silent as to a specific standard provided for flashlights having 2 size "D" cell batteries. The engineers therefore, should examine the requirement and determine the standard of performance necessary to meet what the drafters had in mind when they added the additional language to the final rule.



This interpretation has been prepared by Francis C. Heil, Attorney, Operations Law Branch; Richard C. Beitel, Manager, and has been coordinated with the Air Transportation Division of the Flight Standards Service. I hope this information satisfies your request.



Donald P. Byrne

 

[A Squared]

A point was made on another forum that even though part 121 doesn't specify anything more than *A flashlight*, and 91.503 isn't applicable to a part 121 flight, it is possible, likely even, that the FAA would apply the "2 D-cell" standard to the flashlight requirement in 121.549, since several other regulations in 91 and 135 establish 2 D-cells as the standard. food for thought.

More food for thought.

If I read the information in JAFI's post correctly, the regulation was originally proposed in 1971 (I assume that NPRM 71-32 means it was an NPRM in 1971) flashlight technology has advanced significantly since them. Batteries were almost all the old Zinc-Carbon type which have been pretty muth replaced by alkaline batteries. (can you even buy carbon-zinc batteries any more?) Bulbs were standard filament bulbs.

It is very possible that the performance of a flashlight with a standard filament bulb and 2 Zinc Carbon D Cells can be surpassed by a modern flashlight with smaller more modern cells (alkaline, lithium, etc) and more efficient light elememts (krypton, Xenon, LED etc.) If push ever came to shove with a fed though, you'd better have some pretty hard data to back it up. Interesting that no manufacturer has attempted to market a flashlight to pilots on this angle: "Buy our super Zap LED flashlight, independent laboratory tests have shown that the super-zap provides 200% greater illumination for 150% longer than the 2 d-cell flashlight specified by the FAA and is 50% smaller and 70% lighter!!!". of course a fed might not be inclined to accept the Super-zap company's data on that. On the other hand, if a fed asks to see your flashlight and you reach in your bag and pull out a 2 D-Cell flashlight in working order, that part of the inspection is over, you passed.

 

[igneousy2]

The past few companies I worked for just had a 2 D cell flashlight velcroed or clipped somewhere in the cockpit that the pilots weren't allowed to use on their preflight. much simpler.

 

[A Squared]

THis got me wondering about marketing flashlights to pilots. After a bit of ggogling I only found 2 manufacturers who State that thier flashlight meets FAA requiremetns.

One, the Tektite excursion pro is a 3 d-cell light, so that's a no brainer.

The other is the Surefire executive which takes 2 Lithium batteries and sure fire claims: "...meets the FAA requirements for a mandatory aircrew light." Although they don't offer any data to support that claim.
http://www.surefire.com/maxexp/main/co_disp/displ/pgrfnbr/463/sesent/00

It is interesting to note that Surefire does *not* claim that thier "Aviator" flashlight meets FAA requirements.

 

[Gatorman]

Geesh!!!

Pardon me for being the guy outside the box on this one.....

I find it hard to believe that so much mental effort is spent on this simple regulation. The regulations were not designed to be THAT difficult!

Go to Wally world and pick up a 2 'D' cell flashlight for less that $5 bucks and put this one to bed.
To apease uncle Fed, have a 2 'D' cell flashlight in good working order available when comes out to check on it. It also might be who of you to turn it on and check it every-once-in-awhile. Not that you HAVE to use, but have it available.

 

[Swede]

The reason this thread is going ape-$hit is because most of us are already saddled with kit bags which tip the scales at back-wrenching weights. My own bag contains 2 aircraft manuals, a QRH, and no less than 3 Jeppeson binders, each about 3" across the seam, containing approaches covering the entire United States, Canada, Caribbean, Central and South America down to the equator. The last thing I need is a 4-pound D-cell monstrocity when a mini-maglight with AA cells does the job just fine.

Before I die, I want to fly a paperless-cockpit airplane. "Swede, do you have the latest revision DVD? Plug it into the FMS so we can shoot this approach!" Ahhhh the bliss.

 

[pullmyfinger]

As long as you can see in the dark

you people take this stuff way to seriously....

 

[FlyChicaga]

Home Depot. $5.99 Everready light plastic 2D cell flashlight. Brighter than 2D cell maglights, and $20 cheaper. Not to mention it weighs less than 1 pound.