Forums: Skydiving: Gear and Rigging:
Do MARD Components require TSO Certification?

 

First page Previous page 1 2 3 4 5 Next page Last page  View All

JohnSherman  (D 2105)

Dec 2, 2011, 9:26 AM
Post #1 of 102 (2720 views)
Shortcut
Do MARD Components require TSO Certification? Can't Post

Do the component which make up a Main Assisted Reserve Deployment system require Certification under the TSO system?

Have Fun! Smile


(This post was edited by JohnSherman on Dec 2, 2011, 9:29 AM)


matthewcline  (D 21585)

Dec 2, 2011, 9:31 AM
Post #2 of 102 (2698 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

In reply to:
Do the component which make up a Main Assisted Reserve Deployment system require Certification under the TSO system?

Have Fun! Smile

Personally, I would be calling and asking you this question. But, since the answer to the question is truly not what you seek why dont you just come out with the issue, so we can all discuss it.

Matt


diablopilot  (D License)

Dec 2, 2011, 9:41 AM
Post #3 of 102 (2688 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

My off the cuff answer says yes, in as much as any RSL requires it. In addition, be cause it is so much more invasive in to the operation of the reserve system I believe it needs to be included in the TSO.

Another debate is if it can be added to an existing design through the FSDO minor changes process or does it require a re-TSO'D of the system.


JohnSherman  (D 2105)

Dec 2, 2011, 10:39 AM
Post #4 of 102 (2636 views)
Shortcut
Re: [matthewcline] Do MARD Components require TSO Certification? [In reply to] Can't Post

Quote:
Personally, I would be calling and asking you this question. But, since the answer to the question is truly not what you seek why dont you just come out with the issue, so we can all discuss it.

Matt,

I thought that is what I did. Why don't you respond to the question which invites discussion instead of doubting my motives. I have an opinion on the answer and I figured there were folks out there who might have a differing opinion might like to express it. Do you?

John


JerryBaumchen  (D 1543)

Dec 2, 2011, 11:16 AM
Post #5 of 102 (2607 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

Hi John,

You old Pot Stirrer you. Tongue

Two things come to mind:

1. The SST was TSO'd under C23b ( and still is, I think ); so when you added your RSL much later, did you submit it to the FAA? Angelic

2. Geo. W. Bush once said, 'I am the decider.' In this case, IMO the only decider is the guys/gals employed by the FAA.

Just a thought or two; but should be interesting to see what you get . . .

JerryBaumchen


JohnSherman  (D 2105)

Dec 2, 2011, 12:07 PM
Post #6 of 102 (2563 views)
Shortcut
Re: [JerryBaumchen] Do MARD Components require TSO Certification? [In reply to] Can't Post

Jerry,

Boil, Boil, Cauldron Bubble

Quote:
did you submit it to the FAA?
1. No, I didn't. The reason is, the the RSL "does not interfear with the normal operation of...".
Like an AAD the RSL only activates the ripcord. It does not take place within the deployment process.
The Doctrin of "must not interfere with the normal (Certificated) operation of" is a long since established by the FAA when AAD's were first introduced.

Quote:
IMO the only decider is the guys/gals employed by the FAA.
2. You are absolutly correct. But I am also interested,

BTW: I placard the Racer in TSO C23b but I have TSO's for everything I make in every rendition of the TSO and could placard it anyway I want.
JS


rrmtopo  (C License)

Dec 2, 2011, 2:31 PM
Post #7 of 102 (2513 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

"Like an AAD the RSL only activates the ripcord. It does not take place within the deployment process."

Curious, if the AAD cutter (not AAD pin puller) is placed above the RPC and it traps the closing loop instead of cutting it, doesn't that put part of the AAD directly into the deployment process?


IanHarrop  (C 1152)

Dec 2, 2011, 3:10 PM
Post #8 of 102 (2486 views)
Shortcut
Re: [rrmtopo] Do MARD Components require TSO Certification? [In reply to] Can't Post

In reply to:
"Like an AAD the RSL only activates the ripcord. It does not take place within the deployment process."

Curious, if the AAD cutter (not AAD pin puller) is placed above the RPC and it traps the closing loop instead of cutting it, doesn't that put part of the AAD directly into the deployment process?

And that would be why there was such a clamor about the Argus AAD.

When its cutter failed to fully cut some loops with the potential of interfering with the normal deployment process, or the potential for a partially cut loop breaking fully during a subsequent jump, some manufactures/countries/DZs banned it.


Premier billvon  (D 16479)
Moderator
Dec 2, 2011, 3:15 PM
Post #9 of 102 (2478 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

>The reason is, the the RSL "does not interfear with the normal operation of...".

Didn't a Racer RSL once strangle a reserve after the main was cut away, thus interfering with its operation?


JohnSherman  (D 2105)

Dec 2, 2011, 4:07 PM
Post #10 of 102 (2450 views)
Shortcut
Re: [billvon] Do MARD Components require TSO Certification? [In reply to] Can't Post

Quote:
Didn't a Racer RSL once strangle a reserve after the main was cut away, thus interfering with its operation?

Yes, Because it was used contrary to the instructions written in the owners manual. That's not the "Normal operation of..."


JohnSherman  (D 2105)

Dec 2, 2011, 4:17 PM
Post #11 of 102 (2445 views)
Shortcut
Re: [rrmtopo] Do MARD Components require TSO Certification? [In reply to] Can't Post

Quote:
Curious, if the AAD cutter (not AAD pin puller) is placed above the RPC and it traps the closing loop instead of cutting it, doesn't that put part of the AAD directly into the deployment process?
You bet it does and I have written extensively about this subject. I have in fact petitioned the FAA for relief from the "Mandatory" use of AAD on tandem for this reason.
We provide a caviet with each owners manual warning about this subject. To out and out ban all cutters without a replacement method would not be a good idea. We accepted the curent cutter type of AAD without ever realizing the potential of entrapment. "Too some olt to late smart"!


rrmtopo  (C License)

Dec 2, 2011, 9:14 PM
Post #12 of 102 (2365 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

Thanks gentlemen. Apologies for my lack of recent event knowledge, only been back in the sport a little over a month after a 20 year layoff. As an aerospace engineer I have been voraciously reading what I can to get back up to speed with the sport and get comfortable with equipment advances.

I'll stop the thread hijack John, thanks for your comments. Your expertise has been interesting reading.


councilman24  (D 8631)

Dec 3, 2011, 6:16 AM
Post #13 of 102 (2318 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

As you well know John the current TSO C23d does not require testing of/with a MARD. They didn't exist when it was written. The new TSO C23f will require 24 additional function tests if a MARD is standard or an option.

Ref. PIA TS-135. We have communications with the FAA that this part of the document will be accepted. There is one paragraph that likely won't be. But we won't know until TSO document issues.


JohnSherman  (D 2105)

Dec 3, 2011, 8:19 AM
Post #14 of 102 (2286 views)
Shortcut
Re: [councilman24] Do MARD Components require TSO Certification? [In reply to] Can't Post

Your assumption that I have read TS-135 or know what it says is as wrong as your response. The question is "do they require" which means today, now, real time.
I do, however, appreciate your information because by knowing that PIA has recognized the need for Certification of these devices means they believe that they must be certified.
I agree that they do need it and believe that they are currently not authorized. I believe their manufacturers have jumped the gun by releasing them to the public without Certification.

MARDs preempt the function of the reserve pilot chute and should be Certified as the reserve pilot chute.
I believe that their current use is a violation of the doctrine of “must not interfere with the normal function of…” and that any rigger who packs and seals one could be Cited. Certainly, the Manufacturers who produce rigs with them installed are also in violation. Of course there are no worries on this from the FAA.

The main pilot chute is the only part of a MARD which is doing the work of dragging. What proof is there that it has the capability to generate the necessary drag to extract the bag from the container?

Picture this. A Manufacturer, who is not the developer, purchases such a system and sticks it on their rig whose bag extraction was tested with the reserve pilot chute and now it might depend on the main pilot chute which by intent endures less extraction force and hasn’t been tested or Certified.

Suppose some one replaces their main pilot chute with a “Home Made” of lesser capability. Additionally, an uncontrolled main riser can and has inverted over the main pilot chute rendering it useless. What provisions have been made to prevent this?

I am not talking about the “if come” I am talking about today.

This is potentially a dangerous system which currently has no Certification and should. It has already had more problems than any RSL. I mean “in total” and RSL’s have been around for some 35 years. I know we have some 25 to 30 thousand units in the field. For some 10 years we made it standard on every rig.
There are rigs in the field which will deploy their reserve as fast as a MARD without the complexity of a MARD and I am not talking about just my rig. I just can’t help but wonder if the folks who have investigated incidents involving MARDs ever thought about this.


Iswoopyou  (D 28871)

Dec 3, 2011, 10:07 AM
Post #15 of 102 (2239 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

First off, I say things the way that I see it and NOT at all trying to stir this cauldron, BUT

It seems as though you began this thread to not necessarily see others opinion's, but to persuade others from choosing a MARD system/device.

Obviously you're against it since you and your company do not offer one ,which perhaps may be slowing sales down, and your frustration is understandable. BUT...

With so many MARD's out and about with millions of jumps and yet none having caused any fatalities or hindering any deployments, why make such a big fuss/deal about approval unless your primary goal is to stop others from considering rigs just because of the MARD(their choice good or bad) and therefore consider your containers? If a company offers a product that they believe in and have thoroughly tested for many jumps...... and for some reason it fails then that's their reputation that they are willing to risk and potentially ruin so why bother?

Unless your intentions are purely for debate/investigative/informational reasons i apologize, but I do not see it that way.

fyi: I jumped a Racer for 1,000 jumps which served me well and great value IMO, but just switched for something different. Perhaps all that is needed to boost some sales is some good marketing/advertisement or a much needed updated website?


JerryBaumchen  (D 1543)

Dec 3, 2011, 10:29 AM
Post #16 of 102 (2220 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

Hi John,

Quote:
I believe that their current use is a violation of the doctrine of “must not interfere with the normal function of…”

Not all MARDS do this.

I think it should read:

Quote:
I believe that the design of some MARDs in current use is a violation of the doctrine of “must not interfere with the normal function of…”

There some MARDs that allow the reserve pilot chute to escape without any additional effort or having to break any tacking.

Look at the ground launch of the reserve pilot chute here and you will see that it goes to full bridle extension without any hesitation:

http://www.youtube.com/watch?v=aqxjHOSKTT0

JerryBaumchen

PS) Am I somewhat biased: Yes


pungdjevel

Dec 3, 2011, 10:53 AM
Post #17 of 102 (2211 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

"There are rigs in the field which will deploy their reserve as fast as a MARD without the complexity of a MARD and I am not talking about just my rig."

Care to elaborate on this? As a newbie rigger I’m obviously missing something…
I have watched your videos and I find no proof for such a statement (video currently unavailable, jumpshack.com is giving me some error).

If I remember correctly. I see a complete reserve deployment in just about the same time as a skyhook assisted reserve deployment following a cutaway (approximately 2 seconds).

So far so good, but…

1.
Test jumper is pulling both handles at the same time. I use the two hands on each handle technique and would not be able beet any RSL or MARD for that reason alone.

2.
It takes the freebag 1.5 seconds to reach line stretch. The same as just about every other container on the marked that I know of (I’m a newbie rigger and I haven’t seen a whole of different rigs).
The skyhook accomplish the same in 0.5 seconds. How is this not faster?

3.
The reserve inflation in your video is about 0.5 seconds. Every other reserve inflation I have seen on tape is about 1.5 seconds. (again, I’m a newbie rigger and I haven’t seen a whole lot of them either).
I can’t help but wonder if the reserve inflation in your video could be lethal if deployed at terminal velocity?
The way I see it, the Racer is no faster than any other container. The reserve in your video however is a lot faster. How can any container speed up a reserve inflation?


JohnSherman  (D 2105)

Dec 3, 2011, 10:55 AM
Post #18 of 102 (2209 views)
Shortcut
Re: [JerryBaumchen] Do MARD Components require TSO Certification? [In reply to] Can't Post

Jerry,

Great video! IMO that system probably doesn't need a MARD. It has a good pilot chute launch and low bag extraction.

However, it is clear from the 2nd slide on that the reserve pilot chute is prempted by the MARD system when it is employed, and becomes the de facto reserve pilot chute and as such requires certification.

The act of prempting the Certificated Reserve pilot chute denotes interfearance with the normal operation of the Certified assembly.

The system needs a Cross connector to control the flailing of the off side riser and capture what little drag the malfunctioned main may have.

John


diablopilot  (D License)

Dec 3, 2011, 3:42 PM
Post #19 of 102 (2150 views)
Shortcut
Re: [Iswoopyou] Do MARD Components require TSO Certification? [In reply to] Can't Post

Quote:
With so many MARD's out and about with millions of jumps and yet none having caused any fatalities or hindering any deployments

You may want to check on that statement.


councilman24  (D 8631)

Dec 4, 2011, 10:48 AM
Post #20 of 102 (2069 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

In reply to:
Your assumption that I have read TS-135 or know what it says is as wrong as your response. The question is "do they require" which means today, now, real time.

My response was NOT wrong. I first answered your question. The first sentence of my reply, "As you well know John the current TSO C23d does not require testing of/with a MARD."

I also added what is going to happen with 99% certainty in the near future. They will be included in TSO C23f.

Actually my answer was incomplete. The real answer 'Didn't, Did, Doesn't, Will.' When TSO C23e was issued TSO testing of MARD's was required as they were included in the version of TS-135 referenced. But since C23e was rescinded after about two weeks after TS-135 was rescinded by PIA because the FAA didn't use it in it's entirety the parachute TSO reverted to C23d.

And yes I did assume you had read TS-135 since you submitted two length white papers to the committee for our meeting last summer in St. Louis concerning how it should be written. My mistake.

BTW RSL's ARE part of the CURRENT TSO C23d qualified components. They are defined and as such and testing of their function is required during breakaway tests.


(This post was edited by councilman24 on Dec 4, 2011, 11:17 AM)


Electronaut  (C 38872)

Dec 4, 2011, 11:22 AM
Post #21 of 102 (2058 views)
Shortcut
Re: [councilman24] Do MARD Components require TSO Certification? [In reply to] Can't Post

In reply to:
BTW RSL's ARE part of the CURRENT TSO C23d qualified components. They are defined and as such and testing of their function is required during breakaway tests.

The RSL's stuck out in my mind during my practical: reading through SB's, Sunpath's directions on non-permanent removal of the RSL has to be done by a master rigger; taking off the lanyard and putting on a piece of pile Velcro over the hook on the reserve riser.


JohnSherman  (D 2105)

Dec 4, 2011, 11:46 AM
Post #22 of 102 (2054 views)
Shortcut
Re: [councilman24] Do MARD Components require TSO Certification? [In reply to] Can't Post

Quote:
My response was NOT wrong. I first answered your question. The first sentence of my reply, "As you well know John the current TSO C23d does not require testing of/with a MARD."

You are wrong! Sir, Current standards do require testing. It requires testing of the complete system. If the reserve pilot chute is replaced by a MARD then it, the MARD, must be tested as a reserve pilot chute.

The future isn't good enough. If the sport had to wait on PIA, or USPA for that matter, until all of their priority interest are satisfied. It wouldn't get done.
The work product of PIA is so poor that their last 3 submissions to the FAA have been rejected as submitted.

What has happened to the 12 Reserve failures at 750 feet with the main closed? It’s an agenda item with no movement for 2 years. Good work PIA! I suppose it needs more politicians to muddy the water.


(This post was edited by JohnSherman on Dec 4, 2011, 1:59 PM)


councilman24  (D 8631)

Dec 4, 2011, 1:30 PM
Post #23 of 102 (2011 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

Since neither the TSO C23d or the referenced technical standard AS 8015B mention a MARD it is only YOUR interpretation that they are now required to be part of TSO testing. Obviously the PIA PCSC agrees that the SHOULD be included. It's up to the enforcers of the regulations, the FAA, to interpret them.

In fact a complete assembly is NOT required to be tested and certified together. Section 5 of AS8015b lists components that may be qualified separately. For instance if a RSL is to be qualified for an already existing system only two tests are required. It is true that for many of the tests the rest of the assembly is needed to complete the test.

The FAA has not "rejected" the "last three submissions." A single individual choose, without the proper procedures, to modify the standard document for TSO C23e. When that was recognized by the FAA action was taken. It is true we believe they plan on eliminating ONE paragraph of the current TS 135 document. This is a paragraph (4.3.9.1) that puts forth an alternate rate of decent standard that may result in significant injury to an unconscious jumper. The PIA committee has been divided on this issue, as well as the PIA committee and the FAA. This is the ONLY item that is in debate and may not be accepted in TSO C23f. At least as far as we've been told. A few other language changes that would have made TS-135 U.S. centric were rejected by the committee. We feel that since PIA is an international organization our documents should not be U.S. centric.

By the way if your unsatisfied with PIA you're unsatisfied with yourself, or at least your company. You ARE PIA. PIA is only as good as those member volunteers who show up to do the work.


Premier billvon  (D 16479)
Moderator
Dec 4, 2011, 4:39 PM
Post #24 of 102 (1970 views)
Shortcut
Re: [JohnSherman] Do MARD Components require TSO Certification? [In reply to] Can't Post

>Yes, Because it was used contrary to the instructions written in the owners manual.
>That's not the "Normal operation of..."

Interesting. Does that work for any user error? i.e. if a manual says "reserve should be deployed in a head high position" and the jumper deploys belly to earth, is a failure considered acceptable by the FAA?


-ftp-

Dec 5, 2011, 6:31 AM
Post #25 of 102 (1891 views)
Shortcut
Re: [pungdjevel] Do MARD Components require TSO Certification? [In reply to] Can't Post

In reply to:
"There are rigs in the field which will deploy their reserve as fast as a MARD without the complexity of a MARD and I am not talking about just my rig."

Care to elaborate on this? As a newbie rigger I’m obviously missing something…
I have watched your videos and I find no proof for such a statement (video currently unavailable, jumpshack.com is giving me some error).

If I remember correctly. I see a complete reserve deployment in just about the same time as a skyhook assisted reserve deployment following a cutaway (approximately 2 seconds).

So far so good, but…

1.
Test jumper is pulling both handles at the same time. I use the two hands on each handle technique and would not be able beet any RSL or MARD for that reason alone.

2.
It takes the freebag 1.5 seconds to reach line stretch. The same as just about every other container on the marked that I know of (I’m a newbie rigger and I haven’t seen a whole of different rigs).
The skyhook accomplish the same in 0.5 seconds. How is this not faster?

3.
The reserve inflation in your video is about 0.5 seconds. Every other reserve inflation I have seen on tape is about 1.5 seconds. (again, I’m a newbie rigger and I haven’t seen a whole lot of them either).
I can’t help but wonder if the reserve inflation in your video could be lethal if deployed at terminal velocity?
The way I see it, the Racer is no faster than any other container. The reserve in your video however is a lot faster. How can any container speed up a reserve inflation?

Waiting for JohnSherman's response to this.


First page Previous page 1 2 3 4 5 Next page Last page  View All

Forums : Skydiving : Gear and Rigging

 


Search for (options)