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FAA ruling on life limits

 

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ActionAir  (D License)

Sep 28, 2012, 9:36 AM
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FAA ruling on life limits Can't Post

Attached is the FAA ruling on supposed life limits.
I recommend you print this out and present to your rigger. If you rigger in unwilling to do his job - insect, repack and recertify a parachute, you might suggest that he / she change occupations. Then find yourself a new rigger!
Thanks goes to USPA for following through with this, for its members.
Attachments: FAA ltr-USPA re life limits 8-21-12.pdf (122 KB)


Premier likestojump  (D License)

Sep 28, 2012, 9:40 AM
Post #2 of 70 (8446 views)
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Re: [ActionAir] FAA ruling on life limits [In reply to] Can't Post

A) HELL YA

B) If I am reading this right, it seems like the ParaPhernalia 20 year life recently put in their Softie manual is actually not binding as per FAA for any Softies purchased prior to the manual revision ?


JohnSherman  (D 2105)

Sep 28, 2012, 11:35 AM
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Re: [likestojump] FAA ruling on life limits [In reply to] Can't Post

Quote:
B) If I am reading this right, it seems like the ParaPhernalia 20 year life recently put in their Softie manual is actually not binding as per FAA for any Softies purchased prior to the manual revision ?

The first half is correct but it doesn't matter when or what they put in the manual it is not binding. Nothing they say in the manual is binding. Only a Service Bullitin stating safety concerns and requesting an Airworthyneess Directive and the issuance of that Directive can change the life span. Mike Truffer (Skydiving Mag) did the research some years ago.
If a rig is to have a service life it must be specified in the data package which accompinies the original application. Changing the manual does nothing. The FAA points out, in the last paragraph, it must be by "Service Bullitin" stating Safety Concerns and requesting an "Airworthyness Directive. Just putting it in the manual does nothing

I applaude the work done by Mike and now Randy. It is the correct rule.

Once PIA got a letter from the French Federation stating their equipment had a 20 year life and requesting to know what the life span on American equipment was. PIA responded "120 days" which was the duration of the "Inspection Cycle" at that time.


(This post was edited by JohnSherman on Sep 28, 2012, 2:20 PM)


pchapman  (D 1014)

Sep 28, 2012, 11:44 AM
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Re: [ActionAir] FAA ruling on life limits [In reply to] Can't Post

Thank you for posting. Very interesting!

[edited: Others beat me to these points but anyway:]

There's one important thing the letter states, but which can easily be overlooked.

Note that it says "and sold before a service life was established."

Although the grammar of the whole sentence is slightly messed up, this suggests that if you bought a parachute AFTER a service life was put in the manual, that life does apply.

So an old Softie pilot rig has a potentially unlimited life, but a new one would have whatever limit is now in their manual.

Although it isn't spelled out, the letter seems to imply something else important -- which I wish had be clarified:

Changing the manual doesn't seem to affect the original limitations on the gear. So if a new manual shows a different packing method, the packing method in the old manual is still legal, because that's how the gear was certified. If the manufacturer thinks it is dangerous, they can apply for an AD.

Whether new manuals complement or supersede old manuals, that's a huge issue that riggers have argued about in the past.


(This post was edited by pchapman on Sep 28, 2012, 11:48 AM)


pchapman  (D 1014)

Sep 28, 2012, 11:47 AM
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Re: [ActionAir] FAA ruling on life limits [In reply to] Can't Post

For better accessibility, I've OCR'd the main contents of the letter from the FAA to the USPA:

Quote:
Dear Mr. Ottinger:
This letter is in response to your request for clarification regarding parachute manufacturers establishing a service life beyond the requirements of the Technical Standard Order (TSO) which the parachute was built (TSO-C23b, dated March 29 1962). Members of USPA also maintain that since TSO-C23b, TSO-C23c, and TSO-C23d did not establish a service life, a rigger may extend the life of the system 180 days at a time.

The Federal Aviation Administration (FAA) considers the service life recommended by the manufacturer, a non regulatory requirement for a parachute that meets the standards of TSO-C23b, TSO-C23c, TSO-C23d, and sold before a service life was established.

To hold a parachute owner to a newly established service life required by the manufacturer of a parachute, the manufacturer issues a Service Bulletin with safety concerns and recommends the FAA issue an Airworthiness Directive to establish a regulatory service life.

Thank you for your interest in aviation safety.
Sincerely,

Steven W. Douglas
Manager, Aircraft Maintenance Division

I think I caught any OCR errors but let me know if anything slipped by.


Deci  (D 1046)

Sep 28, 2012, 11:52 AM
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Re: [pchapman] FAA ruling on life limits [In reply to] Can't Post

Nice. Clears things up a bit.


NovaTTT  (D 17887)

Sep 28, 2012, 12:38 PM
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Re: [ActionAir] FAA ruling on life limits [In reply to] Can't Post

This opens a closed case for me.

A GQ Security 350 that I've declined to work on is sitting in a box in my loft waiting for the pilot to come and claim it.

Based on a 02 Dec 2000 document that indicates a 15 year life limit from date of manufacture subject to a critical inspection at 10 years I've not worked on the rig, which is otherwise airworthy after a few minor correction/repairs.

But I don't have and can't locate an original manual for the 350 - only the 150 and 250.

Anyone have an actual 350 manual or know if, as I suppose, the life limit was related to the closure of the company and not part of that manual?


pchapman  (D 1014)

Sep 28, 2012, 1:08 PM
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Re: [NovaTTT] FAA ruling on life limits [In reply to] Can't Post

Aside to the thread:
I actually do seem to have a scanned manual for the 350, from GQ Security USA 1980, that I got through Beatnik.

Just skimming it, I see no life limit.
PM me your email so I can send it.
(I'll also submit it to parachutemanuals.com)


JerryBaumchen  (D 1543)

Sep 28, 2012, 1:27 PM
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Re: [NovaTTT] FAA ruling on life limits [In reply to] Can't Post

Hi Nova,

In the unlikely event that you do not get a manual from Peter, then contact me & I'll make you a copy of mine.

JerryBaumchen

PS) Peter, good for you for putting it on-line.


JohnSherman  (D 2105)

Sep 28, 2012, 2:32 PM
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Re: [pchapman] FAA ruling on life limits [In reply to] Can't Post

Quote:
So an old Softie pilot rig has a potentially unlimited life, but a new one would have whatever limit is now in their manual.

No, just changing the manual does not change the life limit. They must apply for a new TSO with a revised Data package requiring a specified service life or they may do it by AD. But nothing done to the manual changes anything.


JohnSherman  (D 2105)

Sep 28, 2012, 2:38 PM
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Re: [NovaTTT] FAA ruling on life limits [In reply to] Can't Post

Quote:
Anyone have an actual 350 manual or know if, as I suppose, the life limit was related to the closure of the company and not part of that manual?

You bet your buns. The Brits who bought the company didn't want the liability and they tried to dispose of it. It is the reason Truffer did the research.


pchapman  (D 1014)

Sep 28, 2012, 4:19 PM
Post #12 of 70 (8139 views)
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Re: [JohnSherman] FAA ruling on life limits [In reply to] Can't Post

In reply to:
No, just changing the manual does not change the life limit. They must apply for a new TSO with a revised Data package requiring a specified service life or they may do it by AD. But nothing done to the manual changes anything.

I'd really like to believe that, but the FAA statement tends to support the other interpretation. Still, it doesn't necessarily rule out what you are saying.

A canopy sold before a service life is established clearly can't have one added later in a manual.

But then is putting a limit in a manual a restriction on newly produced canopies? Is "establishing" a service life something that can be done in the manual, or as you suggest, it has to be done through the TSO or AD.

After all, the letter does say "To hold a parachute owner to a newly established service life ..." which doesn't clearly specify if it means it applies to owners with old manuals, or owners buying with a new manual.

Given that this issue is so contentious, I'd like to see other evidence suggesting that only a TSO or AD can change hard limits for parachute life etc.


tdog  (D 28800)

Sep 28, 2012, 8:51 PM
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Re: [ActionAir] FAA ruling on life limits [In reply to] Can't Post

Quote:
If you rigger in unwilling to do his job - insect, repack and recertify a parachute, you might suggest that he / she change occupations.

Nice one, I like the tone of that - NOT. Crazy

If a rigging customer of mine can't understand why I would want to limit my own exposure and liability on higher-risk transactions with a $60 repack fee upside and a $1M lawsuit downside, they can find a new rigger and I won't mind at all. They can even swear and yell at me, but I can sleep at night knowing I don't have any liability for my actions.

It is cool that there are clarifications on this subject, but I think a rigger still has the right to refuse service to anyone, for any reason, and still be a professional who is "doing his job" and not being forced to "change occupations."


JohnSherman  (D 2105)

Sep 29, 2012, 12:58 AM
Post #14 of 70 (7995 views)
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Re: [pchapman] FAA ruling on life limits [In reply to] Can't Post

Quote:
But then is putting a limit in a manual a restriction on newly produced canopies? Is "establishing" a service life something that can be done in the manual, or as you suggest, it has to be done through the TSO or AD.

It must be done throught the AD procedure or by submitting a new TSO.

Another point, to expand this ruling. Someone on this thread asked about a change in packing method in the manual. I would suggest it has to do with safety and airworthyness. If the rig/canopy was tested with one pack method and the manufacturer wants to change it to another type they must have a reason. If the reason has safety implications it must be done through the AD procedure or a new TSO. Of course the manufacturer could change from, say, "Flat packing" to "Pro packing" and declair that it has no safety implications. This would probably need to be explained to the FAA ACO who may require a Safety Bullitin.
The Safetry Bullitin is the only official way for the Administrator to notify interested parties about any changes. If a manual were to change without a Safety Bullitin, how would know oficially.


mark  (D 6108)

Sep 29, 2012, 5:05 AM
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Re: [JohnSherman] FAA ruling on life limits [In reply to] Can't Post

In reply to:
It must be done throught the AD procedure or by submitting a new TSO.

Could it be done via "minor change?" That way it wouldn't apply to previously sold equipment, but would apply to new production.

Mark


councilman24  (D 8631)

Sep 29, 2012, 6:35 AM
Post #16 of 70 (7918 views)
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Re: [JohnSherman] FAA ruling on life limits [In reply to] Can't Post

Of course their have been manufacturers that desperately WANTED an AD issued on their parachute equipment and the FAA refused, stating that since it wasn't an aircraft or appliance they could NOT issue an AD for a parachute. We all know they used to but haven't since 1999. The last was the Relative Workshop amp fittings.

So once again one FAA type is saying one thing and another saying that it isn't possible. There have been indications they might be willing to issue a parachute AD again but I don't believe they have.


councilman24  (D 8631)

Sep 29, 2012, 8:54 AM
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

Doesn't a new manual have to be submitted as a minor change normally?


councilman24  (D 8631)

Sep 29, 2012, 9:28 AM
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Re: [NovaTTT] FAA ruling on life limits [In reply to] Can't Post

The 350 does NOT have the life limit in it. The manual for the British version does. See below and attached.

And my Principle Managing Inspector (as an FAA designee) has given me different guidance. IF this is to be THE interpretation of the FAA then it needs to be disseminated as such by the FAA to all inspectors. Telling the USPA doesn't do me any good.

The U.S. 350, British 350 and service bulletins are available at
http://www.ukskydiver.co.uk/...ategory/178-manuals/

US 350 version here.

http://www.ukskydiver.co.uk/...file/2975-model-350/

British A350 with the maintenance notes attached is available here.
http://www.ukskydiver.co.uk/...s/file/2894-a350pdf/
Chapter 2.2, page 10 of the document.
Attachments: securityA350statement.doc.docx (11.3 KB)


Premier skybytch  (D License)

Sep 29, 2012, 10:05 AM
Post #19 of 70 (7862 views)
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Re: [councilman24] FAA ruling on life limits [In reply to] Can't Post

In reply to:
Telling the USPA doesn't do me any good.

Anybody else notice the date on the letter? It's now over a month later and USPA hasn't informed the membership about it. So apparently telling USPA really doesn't do us any good...


NovaTTT  (D 17887)

Sep 29, 2012, 10:23 AM
Post #20 of 70 (7855 views)
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Re: [councilman24] FAA ruling on life limits [In reply to] Can't Post

Thanks to all for the information & help.


stratostar  (Student)

Sep 29, 2012, 11:17 AM
Post #21 of 70 (7839 views)
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Re: [skybytch] FAA ruling on life limits [In reply to] Can't Post

In reply to:
In reply to:
Telling the USPA doesn't do me any good.

Anybody else notice the date on the letter? It's now over a month later and USPA hasn't informed the membership about it. So apparently telling USPA really doesn't do us any good...

Well in a lot of cases I would agree with you, in the past context of USPA. However, did you see the name on the letter and who it was addressed too? Mr Randy Ottinger, Director of Government Relations.

Do you have any idea how much FAA dealings were/have been/ and are, currently on his plate? Do you have any idea just how much FAA shit has been hitting the fan in the time frame your pointing fingers at, a month ago?

While this is an issue of concern to a number of people, who spent time working on this issue, it is small potato's! There were and are much more pressing info that was needed to be put out for the membership, where HQ and the people I'm talking about were begging the membership to take part in the process to help protect the very dropzones and airports we need the use of in order to jump. Along with substantial research and compiling huge volumes in documents to reply, rebut, refute and fend off very harmful attack on our industry.

The membership turn out was little to noneCrazy, big surprise there, with only a handful of people taking part in the process and replying to USPA & the FAA. I think is it safe to say that this info, along with the pending (Oct. 1st.) release of the PLA standards, that USPA will be making a drafted public notice to all member of all the new FAA information and advisory guidance being released.

Also even tho there is this letter, as you can see not all agree with the content and what it means. That says to me, there is another side who will be bitching to the FAA about this, meaning, it's not a done deal, same as the PLA issue.


Premier skybytch  (D License)

Sep 29, 2012, 6:16 PM
Post #22 of 70 (7736 views)
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Re: [stratostar] FAA ruling on life limits [In reply to] Can't Post

In reply to:
Do you have any idea how much FAA dealings were/have been/ and are, currently on his plate? Do you have any idea just how much FAA shit has been hitting the fan in the time frame your pointing fingers at, a month ago?

Sorry, didn't realize it was all that difficult to disseminate information these days.


JohnSherman  (D 2105)

Sep 29, 2012, 7:12 PM
Post #23 of 70 (7710 views)
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

Quote:
Could it be done via "minor change?" That way it wouldn't apply to previously sold equipment, but would apply to new production.

You can't change a service life with a minor change. You might be able to get a pack job by as a minor change but you better be ready to demonstrate that there is no safety implications if asked by the ACO.


diablopilot  (D License)

Sep 29, 2012, 8:28 PM
Post #24 of 70 (7688 views)
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Re: [tdog] FAA ruling on life limits [In reply to] Can't Post

In reply to:
Quote:
If you rigger in unwilling to do his job - insect, repack and recertify a parachute, you might suggest that he / she change occupations.

Nice one, I like the tone of that - NOT. Crazy

If a rigging customer of mine can't understand why I would want to limit my own exposure and liability on higher-risk transactions with a $60 repack fee upside and a $1M lawsuit downside, they can find a new rigger and I won't mind at all. They can even swear and yell at me, but I can sleep at night knowing I don't have any liability for my actions.

It is cool that there are clarifications on this subject, but I think a rigger still has the right to refuse service to anyone, for any reason, and still be a professional who is "doing his job" and not being forced to "change occupations."

Maybe it's all about the way you say no.

If you tell you client you won't touch it because it's 20+ years old irrespective of condition then you are not doing your job.

On the other hand if you inspect said item and are not willing to recertify it's airworthyness for another 180 days because of its CONDITION rather than age, then you are doing the job of a rigger.


tdog  (D 28800)

Sep 29, 2012, 9:30 PM
Post #25 of 70 (7658 views)
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Re: [diablopilot] FAA ruling on life limits [In reply to] Can't Post

In reply to:
Maybe it's all about the way you say no.

If you tell you client you won't touch it because it's 20+ years old irrespective of condition then you are not doing your job.

#1 - as a freelance rigger, (not a factory, DZ, or manufacture rigger) - I don't have a "job" where I have any moral, emotional, financial, or other implied obligation to provide services to anyone. If I was a subcontractor or employee of an organization I may have responsibility to follow their company policy and standards as long as they were not illegal, or quit that employment.

#2 - When I earned my rigger's ticket, no one made me agree to an oath, like Doctors might with the Hippocratic oath, that makes it part of my "job" to certify something I am uncomfortable accepting the risk to certify. I can say no to anything I want (and the customer can find someone who wants to say yes).

#3 - If someone got hurt, there are two possible liability exposures a rigger might face. The FAA enforcement, which this letter may protect against. And the civil wrongful death lawsuit, which this letter does not address. The plaintiff's attorney will argue while the rigger's actions were against the recommendations of the manufacture, and a professional should have followed the manufacturer's instructions... A good lawyer could easily convince a jury that this FAA letter simply covers government enforcement (and it may not even be admissible if the attorney can convince the judge their claims for relief were not related to regulations)... That their client would not be dead but for the actions of the rigger ignoring the time limit recommended by the manufacture, so the rigger's actions are the proximate cause for their client's death...

So, I as a rigger, reserve the right, to simply say, "Dear customer, the manufacture (or PIA/Industry Publications, etc) published a concern with components of this age, so I would rather not pack that parachute. It may be perfectly airworthy, the FAA does not prohibit me from packing it, but I am unwilling to risk it because no one will stand behind my decision if I am wrong. Sorry."


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