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question on packing reserves

 

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AirborneDaddy  (B 36719)

Nov 20, 2005, 3:10 PM
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question on packing reserves Can't Post

hello every one,

I am a senior rigger and I have a few questions about packing reserves.

I had some trouble finding the manual for my reserve so I used the manual for my container to do so. It contained full packing instructions for the chute itself. I resently found the packing inst. for my reserve online and they are a little different. In this case which one takes presadence?

Also if I get e reserve that I cannot find the instructions for do I just pack it because most chutes are packed the same anyway or am I bound by the manuf. instructions?

I would like to get some advise on this subject. I have discussed it with some friends but really did not get any answers.

Thanks, Blue skies


rushmc  (No License)

Nov 20, 2005, 4:35 PM
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Re: [AirborneDaddy] question on packing reserves [In reply to] Can't Post

I was trained that the container manual is the one you use. If things look odd I would advise calling the reserve manufacture but I do not think you will find anything that strange. (famous last words)

I sure you will get a couple of others to respond who have much more knowelege than I do.


IanHarrop  (C 1152)

Nov 20, 2005, 4:55 PM
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Re: [AirborneDaddy] question on packing reserves [In reply to] Can't Post

I think you can find it here, close to the top - about 5 lines down. Smile

http://www.parachuteriggers.com/...g%20instructions.htm


UDSkyJunkie  (D 25746)

Nov 20, 2005, 5:10 PM
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Re: [AirborneDaddy] question on packing reserves [In reply to] Can't Post

Quote:
It contained full packing instructions for the chute itself. I resently found the packing inst. for my reserve online and they are a little different. In this case which one takes presadence?

Some container manufacturers (such as the Relative Workshop) provide packing instructions starting at the point where the reserve is cocooned. Essentially, the reserve manufactuerer provides instructions to lay out, flake, and fold the canopy (or pro-pack), and then the container instructs you on how to get it in the bag. I believe the cocoon is the line where precedence transitions from reserve to harness manufacturer, though as the person above stated, there are others who may give a more complete or better answer.

Quote:
Also if I get e reserve that I cannot find the instructions for do I just pack it because most chutes are packed the same anyway or am I bound by the manuf. instructions?

As a rigger, you ought to know the official answer to this... the law dictates that while packing a reserve, the rigger must have the manufacturer's instructions immediately availible and OPEN TO THE CORRECT PAGE at all times. As such, if you do not have instructions, you cannot pack the reserve at all.

In reality, I think you will find that each rigger has their preferred method of packing, which will either be a reserve-style Pro or "flat-Pro" packjob, and that they will use the same method for all square reserves, regardless of the manufacturer's instructions.


Hooknswoop  (D License)

Nov 20, 2005, 5:26 PM
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Re: [UDSkyJunkie] question on packing reserves [In reply to] Can't Post

Quote:
the law dictates that while packing a reserve, the rigger must have the manufacturer's instructions immediately availible and OPEN TO THE CORRECT PAGE at all times.

I can't find an FAR that says that. The only FAR I can find is Part 65:

"(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has -- "

You don't even have to physiacally have them, just understand them.

Can you reference a different FAR that is more specific?

Quote:
It contained full packing instructions for the chute itself. I resently found the packing inst. for my reserve online and they are a little different. In this case which one takes presadence?

AC-105-2C States:

"a. The assembly or mating of approved parachute components from different manufacturers may be made by a certificated appropriately rated parachute rigger or parachute loft in accordance with the parachute manufacturer's instructions and without further authorization by the manufacturer or the FAA. Specifically, when various parachute components are interchanged, the parachute rigger should follow the canopy manufacturer's instructions as well as the parachute container manufacturer's instructions. However, the container manufacturer's instructions take precedence when there is a conflict between the two."

That only covers assembly though. A lot of riggers apply that to the packing also.

Quote:
Also if I get e reserve that I cannot find the instructions for do I just pack it because most chutes are packed the same anyway or am I bound by the manuf. instructions?

I PRO pack all sport square reserves (xcept for a couple of special cases) because they pack cleaner and open cleaner.

Derek


AirborneDaddy  (B 36719)

Nov 20, 2005, 5:42 PM
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Re: [UDSkyJunkie] question on packing reserves [In reply to] Can't Post

In reality, I think you will find that each rigger has their preferred method of packing, which will either be a reserve-style Pro or "flat-Pro" packjob, and that they will use the same method for all square reserves, regardless of the manufacturer's instructions


That was my big question and I have talked to a few riggers and they pack most reserves the same way. So does this mean that they are violating the CFR or are they just being consistant in useing what works.

I knew the regs when I asked the questions but what I wanted was advise from more experienced riggers because I know that people do not always pack with manual open (which is a military rigger requirement) and they pack their own special way.

I would like some more advise and thank you all for your input.


masterrigger1  (D 14167)

Nov 20, 2005, 6:38 PM
Post #7 of 98 (1904 views)
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Re: [Hooknswoop] question on packing reserves [In reply to] Can't Post

 
Quote:

"(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has -- "

You don't even have to physiacally have them, just understand them.

Yes, you are required to have the instructions on hand.

How can you understand them if you do not have them????

The Harness/Cointainer's instructions take presidance over the canopy manufacturer's instructions always.

MEL
FAA DPRE
FSDO CAE-13


Hooknswoop  (D License)

Nov 20, 2005, 6:42 PM
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Re: [masterrigger1] question on packing reserves [In reply to] Can't Post

Quote:
Yes, you are required to have the instructions on hand.

Show me where it says that in the FAR's.

Quote:
How can you understand them if you do not have them????

I can pack a Javelin, Mirage, or Vector II or III, etc. without opening the manual just like I can pack a main without opening the manual. I don't do that, I have the manual handy as a reference to make sure. But the FAR's don't say you have to have it in front of you, just have to understand the instructions.

Derek


(This post was edited by Hooknswoop on Nov 20, 2005, 6:44 PM)


AirborneDaddy  (B 36719)

Nov 20, 2005, 7:27 PM
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Re: [Hooknswoop] question on packing reserves [In reply to] Can't Post

So I am gathering that from the CFR(FAR) that as long as you understand them you can pack as you see fit as long as you generally follow and "understand" them.


Hooknswoop  (D License)

Nov 20, 2005, 7:32 PM
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Re: [AirborneDaddy] question on packing reserves [In reply to] Can't Post

Quote:
So I am gathering that from the CFR(FAR) that as long as you understand them you can pack as you see fit as long as you generally follow and "understand" them.

If the instructions say flat pack, then you have to flat pack. I think most of the manufacturers have embraced reserve PRO packing. There are exceptions though. As for the instructions, you just have to understand them. Unless someone can show me another FAR that says different. Look through AC-105-2C, Part 65 and 105, and see if you can find anything.

Derek


UDSkyJunkie  (D 25746)

Nov 20, 2005, 8:42 PM
Post #11 of 98 (1848 views)
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Re: [Hooknswoop] question on packing reserves [In reply to] Can't Post

Quote:
I can pack a Javelin, Mirage, or Vector II or III, etc. without opening the manual just like I can pack a main without opening the manual. I don't do that, I have the manual handy as a reference to make sure. But the FAR's don't say you have to have it in front of you, just have to understand the instructions.

You're right insofar as part 65 and 105 do not say any more than that a rigger may not:

(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute; or

(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has—

(1) Performed duties under his certificate for at least 90 days within the preceding 12 months;

So, assuming you "understand" it, and you have "performed duties under your certificate for at least 90 days within the preceding 12 months" (whatever the hell that means), it could be argued that you don't need to open the manual. Unfortunately, that's not how the FAA tends to interperet those regulations, and no offense, but you damn well know it.

Before I took my test, I had a contraband copy of the DPRE test procedures, which we mere mortals aren't allowed to see. I seem to recall reading in them that the applicant must be ON THE PAGE at all times to pass. I could be mistaken, and I no longer have the document to find out. Regardless, my DPRE said strait up he was required by law to fail me if I was not on the page, even though he thought it was silly. Every rigger I know believes that the same holds true if an FAA inspector comes by while you're rigging.... if you're not on the page, then you're in violation of something.

Is it really written in the FAR's? I don't know, and I'm not going to spend a week looking. Is it effectively a law, wether on the books or not? Yes. That's enough for me... if it's not enough for you fine, but I think it's better to tell people the regs, and then tell them what will be expected of them in real life instead of demanding to see it in the FAR. We all know a demand like "show me where it says that in the FAR's" is unlikley to work in the courtroom... they'll find a way to show you, even if it isn't there.


Hooknswoop  (D License)

Nov 20, 2005, 9:25 PM
Post #12 of 98 (1839 views)
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Re: [UDSkyJunkie] question on packing reserves [In reply to] Can't Post

Quote:
Before I took my test, I had a contraband copy of the DPRE test procedures, which we mere mortals aren't allowed to see. I seem to recall reading in them that the applicant must be ON THE PAGE at all times to pass. I could be mistaken, and I no longer have the document to find out. Regardless, my DPRE said strait up he was required by law to fail me if I was not on the page, even though he thought it was silly. Every rigger I know believes that the same holds true if an FAA inspector comes by while you're rigging.... if you're not on the page, then you're in violation of something.

This one?:

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/14c115fcae79293486256ea000572074/$FILE/8610.5J.pdf

Or this one?:

http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-25.pdf

I don’t see in either one where it says you have to have the correct page of the manual open or you fail. It does say you must demonstrate that you can use the manual by flaking and closing the rig according to the manufacturer’s instructions.

Quote:
Is it really written in the FAR's? I don't know, and I'm not going to spend a week looking. Is it effectively a law, wether on the books or not? Yes.

If you do not know if it is an FAR or not, why did you say it was? The rigging FAR's (65 and 105) would take more than 20 minutes to go through, not a week.

What does “effectively a law” mean? It either is or it isn’t. If it isn’t an FAR, then it isn’t an FAR.

Quote:
We all know a demand like "show me where it says that in the FAR's" is unlikley to work in the courtroom... they'll find a way to show you, even if it isn't there.

I would think that would work very well. If it isn’t an FAR, it isn’t an FAR.

Quote:
So, assuming you "understand" it, and you have "performed duties under your certificate for at least 90 days within the preceding 12 months" (whatever the hell that means), it could be argued that you don't need to open the manual. Unfortunately, that's not how the FAA tends to interperet those regulations, and no offense, but you damn well know it.

I don’t damn well know it. There is an FAA Inspector at the Denver FSDO that is up to speed on the FAR’s pertaining to rigging. He doesn’t just make up FAR’s. In my experience, the FAA tends to interpret the FAR’s exactly as they are written. If it doesn’t say you must have the manuals open to the exact page for the step you are on, then you don’t have to. If the FAR’s say a Senior Parachute Rigger may alter a main parachute, then they can.

This is like the discussion about if a reserve is loaded over the TSO’d max weight, is it illegal to jump. According to the FAR’s, yes it is legal. Why? Because there isn’t an FAR that says it isn’t.

An interesting tidbit; It used to be against the FAR’s to skydive under the influence of alcohol, but that FAR was removed.

Derek


(This post was edited by Hooknswoop on Nov 20, 2005, 9:37 PM)


mjosparky  (D 5476)

Nov 20, 2005, 10:20 PM
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Re: [UDSkyJunkie] question on packing reserves [In reply to] Can't Post

See attachments.

Sparky


(This post was edited by mjosparky on Nov 20, 2005, 10:21 PM)
Attachments: faa-g-8082-15a.pdf (40.6 KB)
  FAA-S-8081-25.pdf (87.2 KB)


marinho  (D 26345)

Nov 21, 2005, 4:16 AM
Post #14 of 98 (1776 views)
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Re: [AirborneDaddy] question on packing reserves [In reply to] Can't Post

Just have common sense! If you don't have a manual, get one and get all the information you need to pack yours or anybody's reserve.
At our company, we pretty much have all the manuals we need to pack any reserve on the market.
If there is any question, we just contact the manufacturer and ask for their guidance.
It's very common to see this kind of problem! just remember:
Have a manual on file,
Contact manufacturer,
And finally, have fun!
As I said a long time ago, it's not about what the law says, but your interpretation of the law and how you comply with it!Wink
Cheers,
Augusto Marinho
Rigging Solutions


tso-d_chris

Nov 21, 2005, 7:14 AM
Post #15 of 98 (1725 views)
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Re: [UDSkyJunkie] question on packing reserves [In reply to] Can't Post

In reply to:
We all know a demand like "show me where it says that in the FAR's" is unlikley to work in the courtroom

One would think that is where it is most likely to work. Judges are often reluctant to enforce non-existent laws. If the FAR does not exist, a conviction is unlikely to result in its "violation."


mjosparky  (D 5476)

Nov 21, 2005, 2:58 PM
Post #16 of 98 (1645 views)
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Re: [UDSkyJunkie] question on packing reserves [In reply to] Can't Post

In reply to:
Is it really written in the FAR's? I don't know, and I'm not going to spend a week looking. Is it effectively a law, wether on the books or not? Yes. That's enough for me... if it's not enough for you fine, but I think it's better to tell people the regs, and then tell them what will be expected of them in real life instead of demanding to see it in the FAR. We all know a demand like "show me where it says that in the FAR's" is unlikley to work in the courtroom... they'll find a way to show you, even if it isn't there.

If it is not "on the books" it is not a law. (regulation) The FAA is not going to take you to court if it does not have Part violation to point to. If you are referring to a civil court, all bets are off.

If you are not willing to spend the time reading the FAR’s maybe you should refrain from making decisions on what they say or don’t say.

You do not need to have a copy of the manufacture’s instructions to pack an “approved” parachute or harness/container. It is not a good idea to do so and no one is saying it is. But if you are going to quote regulations, quote them correctly.

Sparky


masterrigger1  (D 14167)

Nov 21, 2005, 4:36 PM
Post #17 of 98 (1633 views)
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Quote:

You do not need to have a copy of the manufacture’s instructions to pack an “approved” parachute or harness/container. It is not a good idea to do so and no one is saying it is. But if you are going to quote regulations, quote them correctly.


Again, yes they are required.
First let us go to This..

§ 65.115 Senior parachute rigger certificate: Experience, knowledge, and skill requirements.
Except as provided in §65.117, an applicant for a senior parachute rigger certificate must—

(a) Present evidence satisfactory to the Administrator that he has packed at least 20 parachutes of each type for which he seeks a rating, in accordance with the manufacturer's instructions and under the supervision of a certificated parachute rigger holding a rating for that type or a person holding an appropriate military rating;

(b) Pass a written test, with respect to parachutes in common use, on—

(1) Their construction, packing, and maintenance;

(2) The manufacturer's instructions;






The test questions (320 of them now) include 4 of which specifically point to having the instructions at hand.

Also, in the FAA/DPRE handbook, Manufacturer's instructions are considered required equipment that is listed through out Part 65.

MEL


UDSkyJunkie  (D 25746)

Nov 21, 2005, 6:46 PM
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Re: [Hooknswoop] question on packing reserves [In reply to] Can't Post

Quote:
You don't even have to physiacally have them, just understand them.

Can you reference a different FAR that is more specific?

No. With respect to the FARs, I think this comes down to interperetation. You and I (I agree with you here, by the way) may say that "understand" just means you have to be familiar with them, work with them regularly, be able to recite them, whatever. Another person, say... a judge... might interperet "understand" to mean "you just read the specific instruction you're about to execute." Who is right? I don't know, but all that matters is what the judge decides.

Quote:
I don’t see in either one where it says you have to have the correct page of the manual open or you fail. It does say you must demonstrate that you can use the manual by flaking and closing the rig according to the manufacturer’s instructions.

Again, this is open to interperetation... my DPRE, as well as the DPRE that the riggers I learned from had, interpereted this to mean the instruction had to be open and to the correct page. Others may be different, I don't know. I wouldn't want to find out the hard way.

Quote:
You do not need to have a copy of the manufacture’s instructions to pack an “approved” parachute or harness/container. It is not a good idea to do so and no one is saying it is. But if you are going to quote regulations, quote them correctly.

Whether or not you need to have them "open" or "on the page," it sure seems to me like you have to have it at least readily availible for reference, and have read them at least once at some point in order to "understand" the instructions. So if you're an experienced rigger with 200 javelin packjobs do you need a manual? Maybe not. If you're an occasional rigger who has never packed a Javelin before, do you need them (that was essentially the situation that started this thread after all)? Yes... because you have to understand them, which means reading them.

This whole mess is about how different people interperet vauge regulations. So far in my experience, two DPRE's, several master riggers, and a couple dozen senior riggers have all told me their interperetation is what I "misquoted." So far exactly two people (admittedly intelligent, current, professionals) have said they interperet them otherwise. I'll side with the mob on this one.


Hooknswoop  (D License)

Nov 21, 2005, 7:05 PM
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Keep in mind what is legal isn't always smart and what is smart isn't always legal.

All the FAR says is you have to understand the instructions. It says nothing about having them, having them open, or having them open to the correct page. That is the letter of the law. Any interpretation beyond that is adding to or changing the FAR. I understand and agree a rigger should have the manual within arm reach while packing a reserve and it should be an FAR, but it isn’t. I personally have spent the money for a binder and page protectors for every manual to make it easy to have open next to me while packing. It lays flat and is easy to flip pages.

The DPRE handbook and Performance Standards do not state that the manual has to be there and open either. It does make sense to do exactly that, especially during your test though.

A few questions from my studying of the FAR’s and TSO’s:

Can you pack a PD-113R into a Mirage?

Can you legally pack a container that the manufacturer has issued a SB for that hasn’t been applied?

Who can alter a main parachute?

Is it against the FAR’s to drink alcohol while packing a reserve?

What are the FAA requirements to be a current Parachutist in Command?

Does the FAA require a FAA medical certificate to act as a Parachutist in Command?

What minimum equipment and training is required by the FAA to jump solo out of an airplane?

Are jump ships operated under part 91 required to follow TBO hour requirements set forth by the engine’s manufacturer?

The FAA couldn’t care less about skydiver’s safety. The FAR’s are in place to protect the public, not skydivers.

Derek


mjosparky  (D 5476)

Nov 22, 2005, 12:41 AM
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Re: [masterrigger1] question on packing reserves [In reply to] Can't Post

Part 65.115 is not about what is required to pack an approved parachute; it is about what is required to that the practical exam for a riggers certificate.

65.115 Senior parachute rigger certificate: Experience, knowledge, and skill requirements.

When you say “FAA/DPRE handbook”, I take it you mean FAA-S-8081-25, Practical Test Standards. “Each Area Of Operation/Task” lists a required Reference. That reference is for use by the Examiner, not the applicant. That might be why they are required to provide them.

Required Material for the Practical Test
The examiner is responsible for supplying all equipment and materials to
support the test.


The REFERENCE identifies the publication(s) that describe(s) the TASK.
Descriptions of TASKs are not included in these standards because this
information can be found in references listed for each TASK. Publications
other than those listed may be used as references if their content conveys
substantially the same meaning as the referenced publications.
References listed in this practical test book include the current revisions of
the following publications.


14 CFR part 1 Definitions and Abbreviations
14 CFR part 21 Certification Procedures for Products and Parts
14 CFR part 43 Maintenance, Preventive Maintenance Rebuilding, and
Alteration
14 CFR part 65 Certification: Airmen Other Than Flight Crewmembers
14 CFR part 91 Air Traffic and General Operating Rules
14 CFR part 105 Parachute Jumping
AC 105-2 Sport Parachute Jumping
TSO-C23b Parachutes
TSO-C23c Personnel Parachute Assemblies
TS 108 Parachute Industry Association Publication
AS 8015B Aerospace Standard
NAS 804 National Aircraft Standards Specification
PPM Poynter Parachute Manual Vol. I, 3rd edition
PPM VOL. II Poynter Parachute Manual Vol. II


The following question is from the current Rigging test bank of questions.

27. A44 RIG
A certificated parachute rigger shall not exercise the privilege of his/her certificate and type ratings unless he/she understands the current manufacturer's instructions for the operation involved and
A) has satisfactorily packed not less than 20 parachutes within the preceding 90 days.
B) has performed duties under his/her certificate for at least 90 days within the preceding 12 months.
C) has performed duties under his/her certificate within the preceding 90 days.


If you know of any FAA reg. that says a certificated rigger has to have the Manufactures Instructions in hand to pack, please post them. I can find nothing in Part 65 or Part 105, the 2 parts that cover riggers and packing.

Sparky


masterrigger1  (D 14167)

Nov 22, 2005, 2:45 AM
Post #21 of 98 (1555 views)
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Re: [mjosparky] question on packing reserves [In reply to] Can't Post

Quote:

In reply to:
Part 65.115 is not about what is required to pack an approved parachute; it is about what is required to that the practical exam for a riggers certificate.

Sure it is! Riggers pack approved parachutes don't they??!!

The knowledge area is tested in regards to the manufacturer's instructions and their use.
The written knowledge test shows that you know and understand the FAR's and their intent.


(b) Pass a written test, with respect to parachutes in common use, on—

(2) The manufacturer's instructions;

Quote:

When you say “FAA/DPRE handbook”, I take it you mean FAA-S-8081-25, Practical Test Standards. “Each Area Of Operation/Task” lists a required Reference. That reference is for use by the Examiner, not the applicant. That might be why they are required to provide them.

No, it is not the PTS handbook. It is an Order Number provided to Inspectors and DPREs. I will have to get the # from the shop later today.

The reference material is required by the examiner because the rigger applicant HAS to use them.

Quote:

If you know of any FAA reg. that says a certificated rigger has to have the Manufactures Instructions in hand to pack, please post them. I can find nothing in Part 65 or Part 105, the 2 parts that cover riggers and packing.

It is in the pre-amble to the rule making. Have your local FSDO Show it to you.

There is a reason you have to READ, speak, and understand the English langage to become a FAA certificated rigger!!


Common sense prevails here!

MEL


Hooknswoop  (D License)

Nov 22, 2005, 5:52 AM
Post #22 of 98 (1524 views)
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Re: [masterrigger1] question on packing reserves [In reply to] Can't Post

Quote:
It is in the pre-amble to the rule making.

Do you mean this document?:

http://dmses.dot.gov/.../pdf35/53725_web.pdf

I couldn't find anything in it. Also, the pre-mable to a NPRM is not an FAR and if it isn't an FAR, then it isn't law.

Derek


masterrigger1  (D 14167)

Nov 22, 2005, 8:42 AM
Post #23 of 98 (1486 views)
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Re: [Hooknswoop] question on packing reserves [In reply to] Can't Post

In reply to:
Quote:
It is in the pre-amble to the rule making.

Do you mean this document?:

http://dmses.dot.gov/.../pdf35/53725_web.pdf

I couldn't find anything in it. Also, the pre-mable to a NPRM is not an FAR and if it isn't an FAR, then it isn't law.

Derek


No, it is not the Pre-amble that I am talking about.

I am glad you went to law schoolWink

Pre-ambles are law! They further define the rule.

Each subpart has a pre-amble. A pre-amble is the subject matter and intent for which the rule is written.

Call Don and get him to give it to you.
MEL


(This post was edited by masterrigger1 on Nov 22, 2005, 8:46 AM)


masterrig  (D License)

Nov 22, 2005, 8:57 AM
Post #24 of 98 (1475 views)
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Re: [masterrigger1] question on packing reserves [In reply to] Can't Post

I have always understood, the harness-container manufacturer, super-cedes the canopy manufacturer's instructions. For instance, Jump Shack is quite adament about pro-packing the reserve going into a Racer. Some manufacturers, will state that they 'prefer' a pro-pack and refer the rigger to the canopy manufacturer's instructions. To me, that leaves it up to the rigger.


Chuck


Hooknswoop  (D License)

Nov 22, 2005, 10:22 AM
Post #25 of 98 (1449 views)
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Re: [masterrigger1] question on packing reserves [In reply to] Can't Post

Quote:
I am glad you went to law school

Same one you went to, I guessLaugh.

Quote:
No, it is not the Pre-amble that I am talking about.

This document?:

http://dmses.dot.gov/...pdf64/128768_web.pdf

You would think if it was law, the FAA would publish it. Otherwise, how can anyone be expected to follow it?

If you have it, what does it say about manuals and reserve packing?

Derek


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