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180 Day Repack news

 

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howardwhite  (C 3896)

Nov 17, 2008, 5:13 PM
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180 Day Repack news Can't Post

USPA has posted on its web site information that the FAA will publish the new rule for the 180-day repack cycle in the Federal Register this week, to take effect 90 days after publication. That would make it take effect sometime around Feb. 17-19, 2009 (just after the PIA Symposium and USPA Board meetings in Reno.)
As the USPA bulletin notes, the rule change results from a joint effort by USPA and PIA.

HW


mdrejhon  (C 3268)

Nov 17, 2008, 5:24 PM
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

Excellent. About time -- this benefits me as I'm a Canadian who travels to the U.S. frequently.

My reserve packjob expires early Feb, so I'll wait until after then (probably not skydiving at all in Feb anyway) to make sure I'm 6 month legal in both countries.


(This post was edited by mdrejhon on Nov 17, 2008, 5:24 PM)


councilman24  (D 8631)

Nov 18, 2008, 6:25 AM
Post #3 of 174 (6485 views)
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

If you read the article on USPA's website closely you'll see that PIA approved a request for a wavier, the intent of which was to collect data. In addition at one point before that PIA had bugeted $15000 to collect test data on repack length. The openness of the FAA to a wavier request delayed implementation of the testing program, along with USPA not taking action to contribute.

PIA, neither Rigging Committee which I was the chair of then, nor the entire PIA ever took a vote or a position on this most recent permanent rule change. The FAA took the petition for a wavier and denied it. Then initiated their own rule change based on it.

The comment period for the rule change was announced after on PIA business meeting and was closed before the next PIA business meeting. As Rigging Committee chair at the time, I chose not to try to take a poll of the rigging committee and submit a comment by the 'committee' or by PIA. One, whe had no formal mechanism to do so. But more importantly depending on the exact membership of the committee at the time the committee's collective opinion may have been against the rule change. Many riggers involved with PIA didn't believe we had the data to support the rule change and had other concerns. Over the years this had been a point of debate within the committee. I don't believe anybody involved in this debate didn't want it changed for financial reasons. Concerns were over reserve material that took a "set" harder than other material lots, other maintainence issues that arrise beyond the reserve canopy pack job, etc.

There were two comments on the rule that looked like they were from PIA. They were not. They were the comments of individuals who identified themselves as PIA. Even though they are members their comments were their personnal comments and not the official position of PIA.

This is not to say that PIA doesn't support the rule change, or does for that matter. But it officially has never taken a position on this rule change. Years ago PIA did take a vote and position. I actually had that document removed from the website because it was out of date. At that time, in the 90's, by a close vote PIA as a body was against the going to a 180 day cycle. But that's ancient history.

AFAIK no one outside of FAA has seen the rule yet. So were not sure how it's worded.

Howard, do you know if the iminent publication was announced by FAA formally or communicated informally? I can't find anything on their website.


Skwrl  (C 36419)

Nov 18, 2008, 7:46 AM
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Re: [councilman24] 180 Day Repack news [In reply to] Can't Post

I suspect the first we will see of it will be the publication in the Federal Register.

For those not familiar with all this non-sense, under the US Administrative Procedures Act, if an administrative agency like the FAA wants to propose a new regulation, it needs to provide notice to the public and the opportunity to comment (typically, 90 days). Agencies give notice by publishing the proposed rule in the Federal Register. You can find the proposed rule on repacks here. http://frwebgate4.access.gpo.gov/...;WAISaction=retrieve The proposed rule is not usually the final (implemented) rule; in fact, the final rule may differ significantly from the proposed rule. Pretty much as long as the final rule is not arbitrary, capricious, or outside of the agency's power, it will be upheld if it's challenged. I'm guessing that none of that will happen here...

When the final rule is issued, I'll post a link to it (unless someone else beats me to it).


MakeItHappen

Nov 18, 2008, 9:21 AM
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

The FAA's take on the issue:
see Docket No.: FAA-2005-21829; Amendment Nos. 91-305, 105-13 RIN 2120-AI85 Parachute Equipment and Packing


.


howardwhite  (C 3896)

Nov 18, 2008, 10:42 AM
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Re: [Skwrl] 180 Day Repack news [In reply to] Can't Post

The FAA has released it. See attachment.
Note that (contrary to earlier info), it will take effect 30 days, not 90 days, following its publication in the Federal Register. So if it's published tomorrow (Wednesday) it would take effect Dec. 19 (if my calendar counting is correct, which it might not be.)
The rule document is interesting reading.

HW
Attachments: 2120_ai85.pdf (57.6 KB)


indyz  (D 28525)

Nov 18, 2008, 10:52 AM
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Re: [MakeItHappen] 180 Day Repack news [In reply to] Can't Post

"We are also providing clarification to any 'experience level' concerns in a different rulemaking that clearly defines who can perform certain parachute repack functions."

Any idea what that additional rule might be?


councilman24  (D 8631)

Nov 18, 2008, 11:23 AM
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

Also, Allen maintained all along this wouldn't be retroactive. But nothing in the rule implies that. The wording changes in 30 days. It must be packed within the preceding 180 days. Looks like a 60 day extension for everything packed 90 days ago to me.


councilman24  (D 8631)

Nov 18, 2008, 11:24 AM
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Re: [indyz] 180 Day Repack news [In reply to] Can't Post

The same folks responsible for this are fixing the "pack, maintain or alter" wording in 65.111. I expect that's what they are referring to. See earlier discussions. I'm too lazy to search for them.


howardwhite  (C 3896)

Nov 18, 2008, 3:02 PM
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Re: [councilman24] 180 Day Repack news [In reply to] Can't Post

I expect that there will be some reasonably official clarification of this matter in the next day or two.

HW


masterrigger1  (D 14167)

Nov 18, 2008, 3:50 PM
Post #11 of 174 (5928 views)
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Re: [indyz] 180 Day Repack news [In reply to] Can't Post

Quote:
"We are also providing clarification to any 'experience level' concerns in a different rulemaking that clearly defines who can perform certain parachute repack functions."

Any idea what that additional rule might be?

Yes!
As the FAR's stand right now, supervised reserve pack jobs cannot be used or "placed in service".

In other words, using a supervised pack job is illegal. It must be packed by a certificated rigger.
This is something I did not know until about 2 years ago.

That rule is currently being reviewed by the FAA for possible change.....


65.111 has already been re-written to reflect it's original intent and will come out at the same time as the 180 day repack cycle.

As far as the 120-180 day conflict:
If the parachute was packed under the 120 day rule, the repack will only be good for 120 days.

If the repack happens when the 180 rule is in effect, 180 days applies.

....i.e., no grandfathering....

At least that is what AFS-350 (Washington) tells me.

BS,
MEL


mark  (D 6108)

Nov 18, 2008, 4:08 PM
Post #12 of 174 (5907 views)
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Re: [masterrigger1] 180 Day Repack news [In reply to] Can't Post

In reply to:
As the FAR's stand right now, supervised reserve pack jobs cannot be used or "placed in service".

In other words, using a supervised pack job is illegal. It must be packed by a certificated rigger.

True, but it's worse than that.

As the FAR's stand right now, the only legally supervised packs are those of main parachutes. Supervising any reserve pack job, for any reason, is not a rigger privilege. In other words, there is no way for an aspiring rigger to get the supervised packs he needs.

it's a good thing the FAA has been ignoring that FAR.

Mark


masterrigger1  (D 14167)

Nov 18, 2008, 4:29 PM
Post #13 of 174 (5880 views)
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Re: [mark] 180 Day Repack news [In reply to] Can't Post

Quote:
True, but it's worse than that.

As the FAR's stand right now, the only legally supervised packs are those of main parachutes. Supervising any reserve pack job, for any reason, is not a rigger privilege. In other words, there is no way for an aspiring rigger to get the supervised packs he needs.

it's a good thing the FAA has been ignoring that FAR.

Actually not true.
If you read into the requirements, it does not state that the supervised pack job is intented to be used.

The certification requirements state that the rigger has to pack 20 pack jobs under the supervision of a rigger with a rating of the same type sought.

That is spelled out.

Again, he/she can pack it for certification purposes, just cannot use it!


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;

BS,
MEL


mark  (D 6108)

Nov 18, 2008, 4:38 PM
Post #14 of 174 (5872 views)
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Re: [masterrigger1] 180 Day Repack news [In reply to] Can't Post

In reply to:
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;

BS,
MEL

Sec. 65.125 Certificates: Privileges

(a) A certificated senior parachute rigger may--
...
(2) Supervise other persons in packing any type of parachute for which that person is rated in accordance with Sec. 105.43(a) or Sec. 105.45(b)(1) of this chapter.

(b) A certificated master parachute rigger may--
[similar language as for senior riggers]


It's right there: riggers may supervise only in accordance with 105.43(a) or 105.45(b)(1), both of which deal only with main parachutes.

So, no supervising any reserve parachutes, for any reason.

Just arguing. Not claiming it makes any sense.Wink

Mark


mark  (D 6108)

Nov 18, 2008, 4:48 PM
Post #15 of 174 (5853 views)
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

Page 9 of the pdf says the change is only to single-harness, dual parachute systems, which excludes tandem systems.

Also, the text of the proposed change (pages 20 and 21) addresses only 105.43; it does not include 105.45 tandem systems.

We'll see when the final rule is published, but we may have a 2-tier system with a 120-day cycle for tandems, 180-day cycle for sport rigs.

Mark


masterrigger1  (D 14167)

Nov 18, 2008, 4:57 PM
Post #16 of 174 (5846 views)
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Re: [mark] 180 Day Repack news [In reply to] Can't Post

Quote:
Sec. 65.125 Certificates: Privileges

(a) A certificated senior parachute rigger may--
...
(2) Supervise other persons in packing any type of parachute for which that person is rated in accordance with Sec. 105.43(a) or Sec. 105.45(b)(1) of this chapter.

(b) A certificated master parachute rigger may--
[similar language as for senior riggers]


It's right there: riggers may supervise only in accordance with 105.43(a) or 105.45(b)(1), both of which deal only with main parachutes.

So, no supervising any reserve parachutes, for any reason.

Just arguing. Not claiming it makes any sense.


Mark,
I just do not see where you are coming from with that being 65.115 is a FAR and allows it below.

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



Also: (re-inserted for completeness)

65.125 Certificates: Privileges.
top
(a) A certificated senior parachute rigger may

(1) Pack or maintain (except for major repair) any type of parachute for which he is rated; and

(2) Supervise other persons in packing any type of parachute for which that person is rated in accordance with 105.43(a) or 105.45(b)(1) of this chapter.

(b) A certificated master parachute rigger may

(1) Pack, maintain, or alter any type of parachute for which he is rated; and

(2) Supervise other persons in packing, maintaining, or altering any type of parachute for which the certificated parachute rigger is rated in accordance with 105.43(a) or 105.45(b)(1) of this chapter.

(c) A certificated parachute rigger need not comply with 65.127 through 65.133 (relating to facilities, equipment, performance standards, records, recent experience, and seal) in packing, maintaining, or altering (if authorized) the main parachute of a dual parachute pack to be used for intentional jumping.



The words/phrase "for which the certificated parachute rigger is rated" is key here.

Riggers are nort rated for mains; only certificated parachutes. Mains are a bonus!

It is a moot point anyway. The FAA does not consider this to be an issue or problem.

BS,
MEL


howardwhite  (C 3896)

Nov 18, 2008, 6:11 PM
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Re: [mark] 180 Day Repack news [In reply to] Can't Post

Added to the list of questions for which clarifications will be sought (and maybe even received) Wednesday.

HW


sunshine  (D License)

Nov 18, 2008, 7:07 PM
Post #18 of 174 (5753 views)
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Re: [masterrigger1] 180 Day Repack news [In reply to] Can't Post

Quote:
As the FAR's stand right now, supervised reserve pack jobs cannot be used or "placed in service".

In other words, using a supervised pack job is illegal. It must be packed by a certificated rigger.
This is something I did not know until about 2 years ago.

Wow, i didn't know that either. Kinda funny that I had a save on a 'supervised repack' before even having my riggers ticket. Smile


RIGGER  (D 7933)

Nov 18, 2008, 9:48 PM
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Re: [masterrigger1] 180 Day Repack news [In reply to] Can't Post

Smile Hi

Sec. 65.125 Certificates: Privileges

(a) A certificated senior parachute rigger may--
...
(2) Supervise other persons in packing any type of parachute for which that person is rated in accordance with Sec. 105.43(a) or Sec. 105.45(b)(1) of this chapter.
------------------------------------------------------------

To my opinion the Senior Rigger supervising others for the 20 reserve repacks should be changed.

It is not logic that a person that got his senior rigger ticket 24 hours ago or so can supervise or train a person packing 20 reserves for the FAA test for the same rating/s he/she holds.

All supervising & reserve repaks training should be done by Master Riggers only & I would say better at a rigging training school which run a "Rigger Training Program" with Master Riggers as instructors.

We all know that there are good senior riggers with a lot of time in the rigging market that can do a great job but if a person like to train others he shuold move to a Master Rigger position.

Being a rigger is much more then 20 repacks under supervision.

All above has nothing to do with main parachutes - this needs to be changed as well & a legal "main parachutes packer" training program should be started & at the final a person will be allowed to pack a main parachute for others without a rigger suprvision. it should based on training & testing the persons which will get a ticket for that from USPA under an agreement with the FAA or from the FAA under "Main Parachute Packer" ticket - it is not so hard to do but need people to think different. some might say it is only a main - well, it is only a main & the FAA put rules on it as well - you can pack for yourself but not for others. people are doing that as a job - why not make it leagl like any other legal job ? it will be better for all DZ, packers, riggers, pilots etc. it just a matter of starting the move with the FAA. Today it should be done under "Direct Supervision" means a real rigger next to the packer.

You might say: if a person want to be a Pro Packer for living he/she can move to a rigging course, got th ticket & work leagal by all means - this is one more way to go.

By the way, why 180 days & not 6 month like others on the planet - much more easy to set the due date.

It is all my opinion & I would like to read comments.

Safe Rigging !!!


(This post was edited by RIGGER on Nov 19, 2008, 12:38 AM)


airtwardo  (D License)

Nov 18, 2008, 11:11 PM
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Re: [RIGGER] 180 Day Repack news [In reply to] Can't Post

Today it should be done under "Direct Supervision" means a real rigger next to the packer.

You mean 'Direct Supervision' doesn't mean somewhere on site like the packers tell me?! Wink


RIGGER  (D 7933)

Nov 19, 2008, 12:25 AM
Post #21 of 174 (5665 views)
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Re: [airtwardo] 180 Day Repack news [In reply to] Can't Post

Smile Hi

Direct Supervision by all means = next to the packer = supervising his packing process.

Be Safe !!!


tombuch  (D 8514)

Nov 19, 2008, 4:29 AM
Post #22 of 174 (5622 views)
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Re: [airtwardo] 180 Day Repack news [In reply to] Can't Post

In reply to:
Today it should be done under "Direct Supervision" means a real rigger next to the packer.


You mean 'Direct Supervision' doesn't mean somewhere on site like the packers tell me?! Wink
See a feature I wrote on this topic for The Ranch S&TA page at: http://theblueskyranch.com/STA.php. It's article 11, called "Who Can Pack a Main Parachute."


howardwhite  (C 3896)

Nov 19, 2008, 5:05 AM
Post #23 of 174 (5604 views)
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

The 180-day repack rule change is published in today's Federal Register. It takes effect Dec. 19.
Text attached (it's essentially the same stuff the FAA posted earlier, but is now official.)

HW
Attachments: E8-27459.pdf (69.6 KB)


pchapman  (D 1014)

Nov 19, 2008, 6:01 AM
Post #24 of 174 (5569 views)
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Re: [howardwhite] 180 Day Repack news [In reply to] Can't Post

Just to get this straight:

1) Tandems stay at 120 days.

However the FAA says it will look at the matter. (The FAA loves to say in response to a lot of questions that something is "beyond the narrow scope of this rulemaking".)

2) Earlier suggestions in dz.com threads were made that previous pack jobs would be only good for 120, yet I don't see language that prevents old pack jobs from automatically becoming good for 180.


mark  (D 6108)

Nov 19, 2008, 6:14 AM
Post #25 of 174 (5562 views)
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Re: [pchapman] 180 Day Repack news [In reply to] Can't Post

In reply to:
Just to get this straight:

1) Tandems stay at 120 days.

However the FAA says it will look at the matter. (The FAA loves to say in response to a lot of questions that something is "beyond the narrow scope of this rulemaking".)

2) Earlier suggestions in dz.com threads were made that previous pack jobs would be only good for 120, yet I don't see language that prevents old pack jobs from automatically becoming good for 180.

I'm sorry for my error earlier in this thread.

As I read the change, tandems will also go to 180 days.

105.45(b)(2) establishes tandem reserve pack requirements "in accordance with Sec. 105.43(b) of this part." 105.43(b) is what was changed, so tandem reserve pack requirements (pack cycle, who can pack) change in synch by reference.

Mark


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