AC 121-33B 1/12/06
AEDs directly to the manufacturer and/or to the FDA Center for Devices and Radiological
Health. AED manufacturers may have resources available to provide the FDA-required
oversight.
For safety purposes, the FAA asks that certificate holders comply with the guidance in
applicable Flight Standards Information Bulletins for Airworthiness, such as FSAW 98-05,
Medical Portable Electronic Devices (PED). Certificate holders must also comply with the
requirements of applicable FAA Technical Standard Orders (TSO) such as TSO-C142, Lithium
Batteries. The devices should be maintained in accordance with manufacturers’ specifications
and should be inspected in accordance with schedules developed under operations specifications.
Currently, AEDs are powered by primary (not rechargeable) lithium batteries. Safety of these
batteries is stressed because extremely energetic materials are used in lithium cells and they are
not intrinsically safe. Safety concerns include the possibility of fire, explosion, and the venting
of toxic or flammable gases.
20. What are acceptable power sources for AEDs?
The FAA requires the power source (e.g., batteries) used to power AEDs to comply with all
requirements in applicable advisory material such as Advisory Circular 91.21-1A Use of Portable
Electronic Devices Aboard Aircraft
(http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/MainFram
e?OpenFrameSet ) ), and in applicable TSOs, such as TSO-C142, Lithium Batteries
(
http://avinfo.faa.gov/tso/tsocur/current.htm).
On March 24, 2005, the FAA amended the regulations for emergency medical equipment to
allow approved power sources that do not have TSO markings to be used in AEDs carried
onboard aircraft (http://dmses.dot.gov/docimages/p80/322276.pdf). AED power sources
manufactured before July 30, 2004, and not TSO marked, may continue to be used until their
expiration date, provided that the power source manufacturer has requested and received from
the FAA a finding of TSO equivalency for its product.
Specifically, part 121, Appendix A, was amended to allow the use of AED power sources that
were manufactured before July 30, 2004, and do not have the TSO marking required, provided
that the manufacturer of the power source has received a finding of equivalency from the
appropriate Aircraft Certification Office (ACO). A manufacturer can seek this determination by
contacting the ACO that issued the TSO approval of its AED power source.
21. Is labeling an AED with the statement “approved for use on aircraft” appropriate?
No. Arbitrary use of the statement "approved for use on aircraft" is not appropriate. It could
lead to a safety problem because toxic gas venting precautions are required before placing AEDs
containing lithium sulfur dioxide batteries in an airplane cabin. The battery manufacturer must
supply a note with the batteries that addresses installation procedures and limitations. Marking
requirements for lithium batteries are defined in part 21, specifically § 21.607(d).
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