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65.111 Revised

 

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masterrigger1  (D 14167)

Jun 3, 2010, 9:05 AM
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65.111 Revised Can't Post

The FAA in Washington has finally sent me a revised rule that clarifies the fact that you have to be an appropriately rated rigger to do work on Main canopies.

Yes, appropriately rated means the by the type of work being done.

Minor=Senior rigger
Major and alterations=Master rigger
It only took about 5 years FCOL.

BS,
MEL
Attachments: 2010-13388.pdf (58.8 KB)


sundevil777  (D License)

Jun 3, 2010, 9:13 AM
Post #2 of 67 (2143 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

This includes packing, correct? So now DZs will have to be ready to claim that packers are actually being supervised by riggers, correct?


JohnRich  (D License)

Jun 3, 2010, 10:03 AM
Post #3 of 67 (2096 views)
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Re: [sundevil777] 65.111 Revised [In reply to] Can't Post

In reply to:
This includes packing, correct? So now DZs will have to be ready to claim that packers are actually being supervised by riggers, correct?

Quote:
"This action amends the requirements for individuals who pack, maintain, or alter main parachutes of a dual-parachute system—those with main and ‘‘back up’’ parachutes—to be used for parachute jumping in connection with civil aircraft of the United States. It expressly limits the authority of a non-certificated person who is not under the supervision of an appropriate current certificated parachute rigger to only pack the main parachute of a dual-parachute system when that person will be the next jumper to use the parachute."
That's the way it's been all along, I believe. If you're packing the main canopy for someone else, then you are required to be under the supervision of a rigger.

Then you get into the whole definitional problem of what constitutes "supervision"...

The main purpose of this change looks like it was to remove the ambiguity in the language that could be misinterpreted to allow non-riggers to perform maintenance on their own canopies.

Packing and maintenance are two different things.


(This post was edited by JohnRich on Jun 3, 2010, 10:09 AM)


mark  (D 6108)

Jun 3, 2010, 10:09 AM
Post #4 of 67 (2086 views)
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Re: [sundevil777] 65.111 Revised [In reply to] Can't Post

In reply to:
This includes packing, correct? So now DZs will have to be ready to claim that packers are actually being supervised by riggers, correct?

No change to that requirement, which is in Part 105.43 and 105.45.

In the past, packers were required to be "directly supervised" by riggers.
Now, packers are still required to be "directly supervised" by riggers.

"Direct supervision" is defined in 105.3, and requires the supervising rigger to personally observe the process to the extent necessary, and to take responsibility for the pack.

Mark


JohnRich  (D License)

Jun 3, 2010, 10:11 AM
Post #5 of 67 (2077 views)
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Re: [mark] 65.111 Revised [In reply to] Can't Post

In reply to:
requires the supervising rigger to personally observe the process to the extent necessary, and to take responsibility for the pack.

Yes. And that doesn't necessarily mean the rigger has to stand there and observe every fold and every line stow of every pack job. If he watches a packer perform his work several times and is satisfied that he is doing it properly, then that is "to the extent necessary".


DiverMike  (C 40024)

Jun 3, 2010, 10:12 AM
Post #6 of 67 (2072 views)
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Re: [JohnRich] 65.111 Revised [In reply to] Can't Post

In reply to:
Then you get into the whole definitional problem of what constitutes "supervision"...

I think the concensus is a rigger has to be onsite and generally sober

"...the FAA believes that adding the word "direct" clarifies the FAA's intent that a certificated rigger must be on the premises during the parachute packing process. The certificated riggers presence ensures that he/she is readily available in person for consultation."


(This post was edited by DiverMike on Jun 3, 2010, 10:12 AM)


riggerpaul  (D 28098)

Jun 3, 2010, 11:02 AM
Post #7 of 67 (2036 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

In reply to:
The FAA in Washington has finally sent me a revised rule that clarifies the fact that you have to be an appropriately rated rigger to do work on Main canopies.

Yes, appropriately rated means the by the type of work being done.

Minor=Senior rigger
Major and alterations=Master rigger
It only took about 5 years FCOL.

BS,
MEL

On the other hand, let us not think that they fixed it all once and for all.

From the document you linked, I quote the following
§ 65.111 Certificate required.

* * * * *

(b) No person may pack any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person—

* * * * *

(c) No person may maintain or alter any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person—
(1) Has an appropriate current certificate issued under this subpart; or
(2) Is under the supervision of a current certificated parachute rigger;
As you say, it is clear from 65.111.c.1 that a rigger himself must be appropriately rated to do the work you mention.

But 65.111.c.2 calls only for a current certificate to be supervising, not an appropriate current certificate.

So they still have left a mistake in their wording of 65.111.c.2, and we are not completely out of the woods yet.


masterrigger1  (D 14167)

Jun 3, 2010, 11:10 AM
Post #8 of 67 (2024 views)
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Re: [riggerpaul] 65.111 Revised [In reply to] Can't Post

Paul,
We have that covered with the ruling in hand.

The ruling is basically part of the, if not THE pre-amble for that rule.

This document was written so that the rules would be clear to all, even if people try to pick little "what-ifs" at it.

Direct supervision is allowed BTW!

Basically, the document that was sent out is the definition of the rule and is to be held up accordingly.

BS,
MEL


(This post was edited by masterrigger1 on Jun 3, 2010, 11:26 AM)


diablopilot  (D License)

Jun 3, 2010, 12:00 PM
Post #9 of 67 (1971 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

Mark, you know I appreciate a lot of what you've done in the sport and industry, and personally I like you, but:

Thanks for nothing. You've addressed a non-issue, done something that only serves to hurt peoples interest and ability to learn.

Why should the owner of a non-TSO piece of equipment NOT be allowed to work on it? Hell, no one in the manufacturing process of that piece of equipment had to get any sort of rating, approval, or certification for it, but now you want to penalize the owners.

It's akin to getting the DOT to say shade tree mechanics must get ASE ratings to work on their own cars.

Thanks for nothing on this one Mark.Unsure


mark  (D 6108)

Jun 3, 2010, 12:16 PM
Post #10 of 67 (1963 views)
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Re: [riggerpaul] 65.111 Revised [In reply to] Can't Post

In reply to:
65.111.c.2 calls only for a current certificate to be supervising, not an appropriate current certificate.

So they still have left a mistake in their wording of 65.111.c.2, and we are not completely out of the woods yet.

65.125(c) exempts riggers from the need to have a type rating to work on a main parachute, so any certificate is an appropriate certificate. (We should take advantage of this by making all the packers get chest-only senior certificates. That way they would be legal to pack without supervision, but they couldn't get in trouble packing reserves or doing maintenance on back-type rigs.)

Interestingly, 65.125(c) also exempts riggers from the need to be current when packing or supervising packing a main parachute, which now conflicts with 65.111(c).

Mark


mark  (D 6108)

Jun 3, 2010, 12:18 PM
Post #11 of 67 (1957 views)
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Re: [diablopilot] 65.111 Revised [In reply to] Can't Post

In reply to:
Mark, you know I appreciate a lot of what you've done in the sport and industry, and personally I like you, but:

Thanks for nothing. You've addressed a non-issue, done something that only serves to hurt peoples interest and ability to learn.

Why should the owner of a non-TSO piece of equipment NOT be allowed to work on it? Hell, no one in the manufacturing process of that piece of equipment had to get any sort of rating, approval, or certification for it, but now you want to penalize the owners.

It's akin to getting the DOT to say shade tree mechanics must get ASE ratings to work on their own cars.

Thanks for nothing on this one Mark.Unsure

Just to be clear, I think you're addressing MEL, not me.

Mark


diablopilot  (D License)

Jun 3, 2010, 12:26 PM
Post #12 of 67 (1949 views)
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Re: [mark] 65.111 Revised [In reply to] Can't Post

Sorry Mark, "MEL"'s first name is Mark too.


AndyMan  (D 25698)

Jun 3, 2010, 12:50 PM
Post #13 of 67 (1932 views)
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Re: [diablopilot] 65.111 Revised [In reply to] Can't Post

Yup, I agree.

I don't think this makes our industry better at all. I think the biggest impact will be to pad the pockets of Master Riggers, who will effectively be taking the work from Senior Riggers all over the country.

I can't help but suspect the people advising the FAA are all Master Riggers.

_Am


masterrigger1  (D 14167)

Jun 3, 2010, 1:27 PM
Post #14 of 67 (1900 views)
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Re: [diablopilot] 65.111 Revised [In reply to] Can't Post

Quote:
Mark, you know I appreciate a lot of what you've done in the sport and industry, and personally I like you, but:

Same here!

Quote:
Why should the owner of a non-TSO piece of equipment NOT be allowed to work on it? Hell, no one in the manufacturing process of that piece of equipment had to get any sort of rating, approval, or certification for it, but now you want to penalize the owners.

It's akin to getting the DOT to say shade tree mechanics must get ASE ratings to work on their own cars.

Thanks for nothing on this one Mark.

Sorry you have that outlook.

I only asked for definition of the rule that was already in place. Period.

In 2001, the rule had the word alter added to it to allow Tandem masters to deviate from the packing instructions..."alter".

People used that word in their best interest and did work that did not meet the rule.
The word "alter" was a mistake in the first place. It even says so it in the document.

So how is it me, helping clear up a mistake that I never made, an issue or problem with you or anyone else?

I will tell you. It takles a way a "thought to be" privilage that I have earned and you (as I am aware) still have yet to do.

Nothing personal though.
You are just the first to complain.

Cheers,
MEL


masterrigger1  (D 14167)

Jun 3, 2010, 1:29 PM
Post #15 of 67 (1897 views)
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Re: [AndyMan] 65.111 Revised [In reply to] Can't Post

Andy,
Hint- Get your Master's ticket and cash In!!Wink

MEL


diablopilot  (D License)

Jun 3, 2010, 1:46 PM
Post #16 of 67 (1879 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

So, if you would be so kind guide me on the process to change the rule. I understand your need to clarify an ambiguous rule, but how about you help me give myself the right to repair, modify, and maintain my own mains.

You realize by seeking this clarification, you've just eliminated my right to change my slinks? Or adjust the length of my brake lines? Not to mention the freedom to replace my own lineset EVEN if it doesn't require sewing (which mine don't).

This is a bad rule, and was never the intent of those that sat down and wrote it to begin with.

And how have I not earned it? Your "rule" still is contradictory. Witness the fact I can call myself a manufacturer, build my own main parachute, but then I can't perform maintenance on said main parachute?

On a personal note, I have more than paid my rigging dues. That I choose not to have a ticket for liability reasons is separate from this.

The FAA is stepping outside their jurisdiction on this one. There are no requirements of certification on the manufacture main parachute, therefore they have no jurisdiction to regulate who works on one.

This rule is akin to the FAA requiring an A&P to sign off on the ladder you use to refuel your airplane.


(This post was edited by diablopilot on Jun 3, 2010, 1:53 PM)


masterrigger1  (D 14167)

Jun 3, 2010, 1:55 PM
Post #17 of 67 (1860 views)
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Re: [diablopilot] 65.111 Revised [In reply to] Can't Post

JP,
Think of it the terms of a pilot's certificate.

Also the amount of hard work that I know you have put into it to get that privilege.

Add in a sceniro like what happened with 65.111.....

Not to mention the fact that a rigger's ticket is not that hard to get anyway.

Cheers,
MEL


AndyMan  (D 25698)

Jun 3, 2010, 1:57 PM
Post #18 of 67 (1857 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

In reply to:
Andy,
Hint- Get your Master's ticket and cash In!

Of course, that's what makes it absurd. I have absolutely no desire to learn anything about chest or seat, but if I want to replace a lower brake line I have find 20 of them to pack? Ridiculous.

We were better off before.

_Am


masterrigger1  (D 14167)

Jun 3, 2010, 2:01 PM
Post #19 of 67 (1851 views)
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Re: [AndyMan] 65.111 Revised [In reply to] Can't Post

Quote:
Of course, that's what makes it absurd. I have absolutely no desire to learn anything about chest or seat, but if I want to replace a lower brake line I have find 20 of them to pack? Ridiculous.

We were better off before.

Depends on who's perspective!

MEL


diablopilot  (D License)

Jun 3, 2010, 2:32 PM
Post #20 of 67 (1816 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

In reply to:
Not to mention the fact that a rigger's ticket is not that hard to get anyway.
L

I know. I've met all the qualifications for one.

How many fatalities can you attribute to non-certified work on main parachutes.

This is still ludicrous. There is no certified standard for a main parachute. Period. How can you say that it must be maintained by a certified individual?


councilman24  (D 8631)

Jun 3, 2010, 2:42 PM
Post #21 of 67 (1817 views)
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Re: [diablopilot] 65.111 Revised [In reply to] Can't Post

First off, this fix, not change, to the CFR's is not MEL's doing alone. I as chairman of the PIA rigging committee pointed out to the FAA many (5) years ago that they screwed up in 2001. This rule is NOT new. It's was there prior to 2001 probably since part 65 was written. (I'd have to review all of the old versions, again, to remind myself when this came in.) In 2001 when the FAA added tandems they rewrote part 65.111 to include tandems. When they rewrote it they screwed up the language and paragraphs so that it read that the next person going to jump it could maintain and alter. THIS WAS NEVER THE INTENT! I, MEL and others pointed out this was a mistake, the FAA agreed and said that an emergency fix would be initiated. No public comment was required because this was simply fixing an editing error of the 2001 change.

MEL's taking more credit, and heat, than he deserves.Wink

Nobody has taken anything away from anybody. The FAA has fixed a mistake they never intended to make.

Now, whether the next person going to jump a canopy, including a student, SHOULD be able to maintain and alter that parachute as they wish is a DIFFERENT debate. Lots of folks can. A lot can't and the results have killed people.

Several years ago I asked a room full of DPRE's, manuf, master rigggers and others if anyone could work on a main. You would recognize all of the names. About half, maybe 2/3 raised their hands saying that was true. They all, when I read the pre 2001 rule, realized that wasn't true. Even though many of older riggers were taught that. What isn't required is the paper work. So, nobody can prove who did what.

Again, nobody took anything away. The 2001 rule was always acknowledged by the FAA as a mistake and the fix has been in the works for 5 years.

And that's right. The manufacturer's need a master rigger on staff to do or supervise maintenance and repairs.

Is it right? Maybe not. But is has been the rule and the intent of the FAA for decades, irregardless of the 2001 mistake.


diablopilot  (D License)

Jun 3, 2010, 2:49 PM
Post #22 of 67 (1806 views)
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Re: [councilman24] 65.111 Revised [In reply to] Can't Post

So you knew the 2001 rule was both flawed and in error. Why fix the errors only to leave the flaws?

Show me where people have been killed by non-certified individuals rigging on mains.

The problem this opens is one of jurisdiction. You really think Mr. Kim Barnette knows a P/C from a toggle? Nope, but when he realizes the gaff that this rule is, maybe he decides that some oversight of main parachutes is in order.


That ladder just went from $39.95 to $2500. Thanks.


riggerpaul  (D 28098)

Jun 3, 2010, 3:05 PM
Post #23 of 67 (1797 views)
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Re: [masterrigger1] 65.111 Revised [In reply to] Can't Post

In reply to:
Paul,
We have that covered with the ruling in hand.

The ruling is basically part of the, if not THE pre-amble for that rule.

This document was written so that the rules would be clear to all, even if people try to pick little "what-ifs" at it.

Direct supervision is allowed BTW!

Basically, the document that was sent out is the definition of the rule and is to be held up accordingly.

BS,
MEL

Yes, with the ruling in hand it is clear what the intention was.

Still, the FARs are also intended to stand alone, so that a person can read the regulation and see the intent.

Reading the new regulation in the absence of the supporting ruling, one must wonder why they were clear that the certificate must be appropriate in 105.65.111.c.1, but failed to include the identical language in 105.65.111.c.2, which is, after all, the very next paragraph.

The language was there to be incorporated.

How is it that in a 5 year process, nobody thought to eliminate that opportunity for confusion?

To be clear, I do not believe that I have ever asserted that there was an intent to allow non-certified persons to pack and maintain main parachutes, except that packing was allowed if the packer was the next jumper. The 2001 changes were wrong to include language that could be interpreted that way.

But, the new supporting document also clearly says that it was possible to interpret the 2001 regulation that way, though it was not the the intent of the 2001 change.

I will assert that the new change, while not so egregiously confused as the 2001 change, still leads the reader to incorrect conclusions.

As such, I am dissatisfied with the new change.


(This post was edited by riggerpaul on Jun 3, 2010, 3:45 PM)


AggieDave  (D License)

Jun 3, 2010, 3:32 PM
Post #24 of 67 (1776 views)
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Re: [diablopilot] 65.111 Revised [In reply to] Can't Post

How far does this go? From the lines to the d-ring? From the riser to the pilot chute? Can I still change my own rubber bands on the d-bag? Or do I need to be a 33rd degree grand rigger?


Bertt  (D 99999)

Jun 3, 2010, 3:54 PM
Post #25 of 67 (1753 views)
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Re: [mark] 65.111 Revised [In reply to] Can't Post

"...making all packers get chest-only senior certificates"
Wouldn't that be a great use for the lap rating?

I agree with AggieDave. There has to be a provision for some "user maintenance".


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