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FAA ruling on life limits

 

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mark  (D 6108)

Sep 30, 2012, 7:30 AM
Post #26 of 70 (4919 views)
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Re: [diablopilot] FAA ruling on life limits [In reply to] Can't Post

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

Riggers do not certify future airworthiness. All we do is certify airworthiness at the time of packing.

Mark


riggermick  (D 17071)

Sep 30, 2012, 3:47 PM
Post #27 of 70 (4863 views)
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

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

Riggers do not certify future airworthiness. All we do is certify airworthiness at the time of packing.

Mark

that means for the next 180 days. Aka the (short term) future. Like it or not, that's how it is. @ 181 days your'e in the clear. But you already know thatSly


ActionAir  (D License)

Sep 30, 2012, 4:23 PM
Post #28 of 70 (4848 views)
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Re: [riggermick] FAA ruling on life limits [In reply to] Can't Post

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

Riggers do not certify future airworthiness. All we do is certify airworthiness at the time of packing.

Mark

that means for the next 180 days. Aka the (short term) future. Like it or not, that's how it is. @ 181 days your'e in the clear. But you already know thatSly

Actually when you sign and seal the rig you are certifying that it is airworthy at that moment. Once you return it to the owner, you have no control over it. So if someone cuts the harness or pokes a hole in the container / canopy, its on the user not the rigger.


mark  (D 6108)

Sep 30, 2012, 4:24 PM
Post #29 of 70 (4845 views)
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Re: [riggermick] FAA ruling on life limits [In reply to] Can't Post

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

Riggers do not certify future airworthiness. All we do is certify airworthiness at the time of packing.

Mark

that means for the next 180 days. Aka the (short term) future. Like it or not, that's how it is. @ 181 days your'e in the clear. But you already know thatSly

No, it does not mean for the next 180 days. It means exactly what I wrote: airworthy at the time of packing only. I cannot know if the rig will be airworthy even tomorrow. Who can certify the future? Further, the regulations permit me to pack something I know will not be airworthy for a full 180 days.

Mark


riggermick  (D 17071)

Sep 30, 2012, 4:39 PM
Post #30 of 70 (4835 views)
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Re: [ActionAir] FAA ruling on life limits [In reply to] Can't Post

Ray pm me with your cell ill do the same. Long time no talk. Lets catch up .
Mick.


skypuppy  (D 347)

Sep 30, 2012, 8:06 PM
Post #31 of 70 (4794 views)
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Re: [pchapman] FAA ruling on life limits [In reply to] Can't Post

seems to me Peter the next paragraph states pretty specifically that adding a service life in the manual is NOT binding -- it would have to be in a service bulletin and airworthiness directive through the FAA


(This post was edited by skypuppy on Sep 30, 2012, 8:08 PM)


pchapman  (D 1014)

Sep 30, 2012, 8:45 PM
Post #32 of 70 (4781 views)
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Re: [skypuppy] FAA ruling on life limits [In reply to] Can't Post

The problem is that it mentions a "newly established" service life. Does that mean newly established since the TSO, or newly established since your rig's manual was published? The company could say that it isn't a newly established service life but the original one appropriate to the serial number of the gear being sold, just like any other change they put in the manual.

And, it isn't clear whether that "next paragraph" is supposed to stand independent of the previous paragraph, or refer to the situation in that previous paragraph, which talked about cases where a service life was changed after a particular item was sold.

Most damningly, why would they even include "and sold before a service life was established", if the following paragraph means that it doesn't matter? That "sold before" quote seems to imply (but does not state) that something might be different for rigs sold after the manual was changed.

It's like saying "Persons over 18 may vote". That says nothing about persons under 18, but is taken to imply that something might be different for them.

Or do they mean "a parachute" as a TSO'd type, rather than an individual physical item? In that case the stuff about "a parachute [type] ... sold before a service life was established" would mean that as soon as that type of parachute was on the market, any changes to service life in the manual have no regulatory force.


The trend of the opinions in this thread certainly is towards "you can't change the original TSO limits with the manual", which is fine by me.

But I personally still think the FAA statement can quite reasonably be interpreted different ways, which makes it so maddening...


fcajump  (D 15598)

Oct 1, 2012, 8:27 AM
Post #33 of 70 (4712 views)
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Re: [tdog] FAA ruling on life limits [In reply to] Can't Post

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

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

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

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

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

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

+1

To the earlier poster -
My JOB is (as a rigger) is to certify that at the time I saw it it was airworthy and serviced in accordance with the FAA regulations, manufacturer's requirements and recommendations, and my company's policy concerning any further limits on condition and/or age. We warrent no future condition, though we note that you are required by the FAA to have it inspected again at 180 days (for use in the USA). At my discression, I may refuse to service any rig, of any age, for any reason I see fit (including applicability for stated/intended use and/or customer attitude).

That sir, is my job as described by my employer (an LLC, of which I am the principle owner)

There is no requirement for me to do anything more.

Freelance Rigger,
JW

PS - I do appreciate getting a copy of the FAA letter. May (or may not) change what I choose to do with regard to my own/old gear, but not what I choose to service for others.


(This post was edited by fcajump on Oct 1, 2012, 8:30 AM)


fcajump  (D 15598)

Oct 1, 2012, 8:36 AM
Post #34 of 70 (4703 views)
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

In reply to:
No, it does not mean for the next 180 days. It means exactly what I wrote: airworthy at the time of packing only. I cannot know if the rig will be airworthy even tomorrow.

Agree 100%.
I understand that this is based on how FAA mechanics' work is seen. Airworthy at the time of inspection. Brakes or tires (for example) that meet the minimum inspection standard are not warrenteed to last the full inspection cycle regardless of how much they are used and how they are treated... only that they meet minimums today.
Parachute owners/users are still required to ensure it is kept in good condition and perform pre-flight inspections to verify that it is still airworthy at the time of use.


Premier billvon  (D 16479)
Moderator
Oct 1, 2012, 9:24 AM
Post #35 of 70 (4680 views)
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

>No, it does not mean for the next 180 days. It means exactly what I
>wrote: airworthy at the time of packing only.

If a rigger knowingly and intentionally signed off on an I/R where he knew the harness would last another few jumps, but fail shortly after that, then he would (rightly) be subject to action if anyone was injured or killed as a result. A harness/container/reserve that is only airworthy for a short time (assuming normal usage) is not airworthy. And to quantify "short time" the rigger has to know how long it will be in use for.

Riggers pack knowing what length of time wear items will last. That's why you hear "this is the last I+R I'm going to do on that unless you get your legstraps fixed; the wear on the legstrap junction is getting to be an issue." And that's why many rigger's standards changed when the 180 day repack cycle came into effect.


mark  (D 6108)

Oct 1, 2012, 10:01 AM
Post #36 of 70 (4668 views)
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Re: [billvon] FAA ruling on life limits [In reply to] Can't Post

In reply to:
If a rigger knowingly and intentionally signed off on an I/R where he knew the harness would last another few jumps, but fail shortly after that, then he would (rightly) be subject to action if anyone was injured or killed as a result. A harness/container/reserve that is only airworthy for a short time (assuming normal usage) is not airworthy. And to quantify "short time" the rigger has to know how long it will be in use for.

Riggers pack knowing what length of time wear items will last. That's why you hear "this is the last I+R I'm going to do on that unless you get your legstraps fixed; the wear on the legstrap junction is getting to be an issue." And that's why many rigger's standards changed when the 180 day repack cycle came into effect.

Your hypothetical rigger might say instead, "Your leg strap junction is airworthy right now. Here's what to look for that would make it unairworthy. If that happens, stop jumping it and bring it back for repair."

As to whether a rig that will be airworthy for only a short period of time is defacto unairworthy, I think we will agree that it's okay to pack a rig for water jumps, and it's okay to pack a student or tandem rig when the AAD will need service after the end of the jump season but before the passage of 180 days.

As to your particular example of a harness that could be expected to last only some number of jumps, I'm at a loss as to how one would even start estimating the number of jumps, or how one might keep track of jumps to be made in the future, or what one's responsibility might be if the equipment is loaned or sold. Jeepers. If there's a problem with airworthiness, the solution is to fix the problem or refuse to return the equipment to service.

Mark


Mark


Premier billvon  (D 16479)
Moderator
Oct 1, 2012, 4:40 PM
Post #37 of 70 (4604 views)
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

>Your hypothetical rigger might say instead, "Your leg strap junction is
>airworthy right now. Here's what to look for that would make it unairworthy.
>If that happens, stop jumping it and bring it back for repair."

Yes, he might say that. And if the customer did not, and the harness failed after 10 jumps due to that same wear worsening . . . they would be, in my opinion, a shitty rigger.

> If there's a problem with airworthiness, the solution is to fix the problem
>or refuse to return the equipment to service.

In the real world you see extremes between perfect and unairworthy. The legstrap example is an easy one; a pattern of worsening wear might indeed require grounding. Or it might be OK for another 1000 jumps. Or it might be marginal - but very close to unairworthy. Most riggers know the difference.


mark  (D 6108)

Oct 1, 2012, 5:45 PM
Post #38 of 70 (4583 views)
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Re: [billvon] FAA ruling on life limits [In reply to] Can't Post

In reply to:
>Your hypothetical rigger might say instead, "Your leg strap junction is
>airworthy right now. Here's what to look for that would make it unairworthy.
>If that happens, stop jumping it and bring it back for repair."

Yes, he might say that. And if the customer did not, and the harness failed after 10 jumps due to that same wear worsening . . . they would be, in my opinion, a shitty rigger.

Whose responsibility was it to inspect the gear to deem it airworthy on that 10th jump?

Mark.


jumpwally  (D License)

Oct 2, 2012, 10:49 AM
Post #39 of 70 (4496 views)
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Re: [tdog] FAA ruling on life limits [In reply to] Can't Post

+1 i just don't get people's facination with old gear,,,dump it,,save up and buy new or newer. It's your life on the line.....Crazy


likestojump  (D License)

Oct 2, 2012, 11:10 AM
Post #40 of 70 (4488 views)
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Re: [jumpwally] FAA ruling on life limits [In reply to] Can't Post

In reply to:
+1 i just don't get people's facination with old gear,,,dump it,,save up and buy new or newer. It's your life on the line.....Crazy

old gear has completely acceptable purposes :

vintage jumps
CRW work
water jumps
etc.

I wouldn't call it fascination.

For example, how would you feel if doctors refused you service because they thought you were too old and required much more work than a younger person ?


SStewart  (D 10405)

Oct 2, 2012, 10:21 PM
Post #41 of 70 (4430 views)
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Re: [likestojump] FAA ruling on life limits [In reply to] Can't Post

Yep!

The gear I jump now has some components dating back to the 90's but most of it is fairly new.

That said, I jumped out of a 1958 Cessna 182 last weekend and it appeared to be in very nice condition and flew like a champ. Obviously well maintained.

If you know what I mean. Wink


skyjumpenfool  (Student)

Oct 3, 2012, 6:14 AM
Post #42 of 70 (4397 views)
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Re: [jumpwally] FAA ruling on life limits [In reply to] Can't Post

In reply to:
+1 i just don't get people's facination with old gear,,,dump it,,save up and buy new or newer. It's your life on the line.....Crazy

I don't think it's a fascination. I'm not a rigger!! I try to find the best rigger I can. Someone I can totally trust. And then, take his advice and listen when he tells me something.

I know a very well respected rigger (name withheld to protect Mark Wink ) who told me he would not repack my old Javelin because it was old enough to drink leagally. He explaned, it was in good shape and probly be ok. However, "this is his policy".

I have that rig packed by another rigger. It's now used as my back up rig because Rigger #1 convinced me I should start looking for new gear. Advice I took.

As I see it, from a non-riggers perspective, any rigger can refuse to pack any gear for any reason. Cool


Premier 554

Oct 3, 2012, 10:45 AM
Post #43 of 70 (4357 views)
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Re: [skyjumpenfool] FAA ruling on life limits [In reply to] Can't Post

Let me see if I understand what you said. You find the best rigger you can. Somone you totally trust. When they refuse to pack your rig, you take it to someone else who will pack it. Is that right? Do you still take your primary rig to rigger #1?


likestojump  (D License)

Oct 3, 2012, 11:22 AM
Post #44 of 70 (4343 views)
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Re: [skyjumpenfool] FAA ruling on life limits [In reply to] Can't Post

In reply to:
In reply to:
+1 i just don't get people's facination with old gear,,,dump it,,save up and buy new or newer. It's your life on the line.....Crazy

I don't think it's a fascination. I'm not a rigger!! I try to find the best rigger I can. Someone I can totally trust. And then, take his advice and listen when he tells me something.

I know a very well respected rigger (name withheld to protect Mark Wink ) who told me he would not repack my old Javelin because it was old enough to drink leagally. He explaned, it was in good shape and probly be ok. However, "this is his policy".

I have that rig packed by another rigger. It's now used as my back up rig because Rigger #1 convinced me I should start looking for new gear. Advice I took.

As I see it, from a non-riggers perspective, any rigger can refuse to pack any gear for any reason. Cool

Their excuse is equivalent of one dismissing their rigger because "they are old enough to collect Social Security".

Plain god damn stupid.


Premier billvon  (D 16479)
Moderator
Oct 3, 2012, 11:32 AM
Post #45 of 70 (4340 views)
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Re: [mark] FAA ruling on life limits [In reply to] Can't Post

>Whose responsibility was it to inspect the gear to deem it airworthy on that 10th jump?

Legally? No one.

Whose responsibility is it to inspect the gear and deem it airworthy for the purpose it will be used for during the I+R? The rigger who inspected and repacked it. "I didn't expect him to jump it 11 times!" will probably not save your ticket, nor will "but I told him it might fail after 10 jumps!" Making 11 jumps on the rig is a reasonable usage of the gear that (the FAA will claim) a competent rigger will foresee.


mark  (D 6108)

Oct 3, 2012, 12:27 PM
Post #46 of 70 (4322 views)
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Re: [billvon] FAA ruling on life limits [In reply to] Can't Post

In reply to:
>Whose responsibility was it to inspect the gear to deem it airworthy on that 10th jump?

Legally? No one.

Whose responsibility is it to inspect the gear and deem it airworthy for the purpose it will be used for during the I+R? The rigger who inspected and repacked it.

I can't believe you intend to imply that a jumper is not responsible for inspecting his own gear.

As to whose responsibility it is to deem something airworthy "for the purpose it will be used for during the I&R," all the rigger who inspected and repacked it is legally required to do is to certify it is airworthy at the time of packing. That really is the FAA position. No rigger is required to certify that anything will be airworthy in the future.

Mark


(This post was edited by mark on Oct 3, 2012, 12:41 PM)


skyjumpenfool  (Student)

Oct 3, 2012, 12:54 PM
Post #47 of 70 (4311 views)
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Re: [554] FAA ruling on life limits [In reply to] Can't Post

In reply to:
Let me see if I understand what you said. You find the best rigger you can. Somone you totally trust. When they refuse to pack your rig, you take it to someone else who will pack it. Is that right? Do you still take your primary rig to rigger #1?

You did misunderstand. I probably did not make my point clear??
Rigger #1 told me that my old Javelin was old enough to drink legally. And, it's his policy not to do any work or I&R on rigs of this age. He went on to say that I could continue to use this rig because it was in good shape (airworthy). However, I'd have to find a new rigger to pack it.

I respect his RIGHT to enforce this policy. I'm sad that he wont pack this rig because I trust him and know he is extremely thorough. But, its his policy and I respect that. My point. Riggers, as I understand this, can choose not to pack or work on any rig at any time for any reason.

And yes, I do still use Rigger #1 whenever possible. I also go to others as needed. Cool


riggermick  (D 17071)

Oct 4, 2012, 5:09 PM
Post #48 of 70 (4217 views)
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Re: [fcajump] FAA ruling on life limits [In reply to] Can't Post

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

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

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

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

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

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

+1

To the earlier poster -
My JOB is (as a rigger) is to certify that at the time I saw it it was airworthy and serviced in accordance with the FAA regulations, manufacturer's requirements and recommendations, and my company's policy concerning any further limits on condition and/or age. We warrent no future condition, though we note that you are required by the FAA to have it inspected again at 180 days (for use in the USA). At my discression, I may refuse to service any rig, of any age, for any reason I see fit (including applicability for stated/intended use and/or customer attitude).

That sir, is my job as described by my employer (an LLC, of which I am the principle owner)

There is no requirement for me to do anything more.

Freelance Rigger,
JW

PS - I do appreciate getting a copy of the FAA .letter. May (or may not) change what I choose to do with regard to my own/old aygear, but not what' I choose to service for others.


Ahhh, at least one of you got it. It's about your liability. With the exception of Ray, how many of the posting pundits have been draged through a superior court room? I have, so has Ray, it aint no fun. i can tell you that. The letter of the law and the "sprit of the law" are both given equal weight in a writ before the courts. Just because you followed the letter of the law doesn't make you immune from prosicuction/ liability, it's your actions that count more than anything else, if you made a bad choice then you have to live with the consequences of your actions. So basicly, you sign off on it you're responsable for it, barring any outside interference. That is how the justice system sees it. Not my rules, theirs ( the voters/ populace). Sorry to knock a hole in your logic/ world view, that's just the way it is. I don't like it either.

Mick.


riggerrob  (D 14840)

Oct 5, 2012, 10:40 AM
Post #49 of 70 (4144 views)
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Re: [pchapman] FAA ruling on life limits [In reply to] Can't Post

The primary reason National put a 15 year life on their parachutes was to ground all those old Phantoms and 26 Lopos that were mentioned in the - late 1980s - acid mesh recall.

Adventure Sports Loft (Perris Valley, California)refused to repack any parachute more than 25 years old because that is how fast they wear out in the Southern California desert.

Butler refused to repack any parachute more than 20 years old, because that is how fast parachutes wear out in the Southern California desert.

GQ Security established life limits in an effort to grouand all of their SACs and 26 Lopos that were mentioned in teh acid mesh recall.

Pioneer orphaned all their round reserves mentioned int eh acid mesh recall.

Personally I would like to see all the round reserves - mentioned in the acid mesh recall - grounded. Even if they were never acidic, 25 years of tensile testing has weakened the fabric.
I also advise new riggers not to waste their money buying bromocreasal green, etc. to test round canopies suspected of acid mesh.

Furthermore, I believe that all reserves certified under TSO C23B, Low Speed category should be retired.


sundevil777  (D License)

Oct 5, 2012, 3:56 PM
Post #50 of 70 (4096 views)
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Re: [riggerrob] FAA ruling on life limits [In reply to] Can't Post

In reply to:
25 years of tensile testing has weakened the fabric.

The tensile testing is not repeated on the same area, correct? Does the area tested get marked, and how?

Your statement would imply that the PD requirement to repeatedly tensile test reserves (it is every year?) is not wise.


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