PD-113R into a Mirage/TSO issues?

[Hooknswoop 19]

AC-105-2C 11e states:

“The strength of the harness must always be equal to or greater than the maximum force generated by the canopy during certification tests.

(1) In a case where the harness is certificated under TSO-C23b and the canopy under TSO C23c, the maximum generated force of the harness and container; i.e, Low-Speed Category (3,000 lbs.) and Standard Category (5,000 lbs.). In this instance, no additional marking on the container is necessary.

(2) In the case where the canopy is certificated under the TSO-C23b and the harness under TSO-C23c, the strength of the harness must be equal to or greater than the certificated category force of the canopy”

A PD-113R label shows the average peak force of 3639 pounds.

The Mirage is TSO’d under TSO-C23b, Low-Speed Category (3,000lbs.).

The way I am reading this is according to AC-105-2C, a PD-113R cannot be put into a Mirage. That also means any reserve TSO'd under TSO-C23d with an average peak force over 3,000 pounds can't go into a Mirage. What am I missing. Thoughts?

Derek

[scdrnr 0]

I think you are technically correct.

Yet another case of silly FAA jargon preventing knowledgable people from doing what is demonstratably safe and accepted. I'm sure you would agree that a Mirage harness is signifigantly stronger than its C23b Low-Speed rating would suggest.

Unless Mirage upgrades its TSO rating I think, that putting a PD-113R in it would be contrary to the letter of the law.

However, I wouldn't lose sleep doing it anyway, because I think one could make two arguments based on the premise that AC-105-2C is not technically an FAR, it is only the FAA's interpretation of the FAR's (I realize that in effect that makes it law).

1. Mirage, the manufacturer, offers the rig with PD reserves installed, making it a factory available configuration that you are simply duplicating - placing responsibility for compatibilty back to the manufacturer.

2. Using #4 Rapide Links rated at 400lbs each should limit the amount of force the canopy imparts on the harness. Clearly the intent of the language is to make sure that the harness does not fail before the parachute, and nowhere in the AC, NAS 804, or AS 8015a does it state what part connector links belong to: the harness or the canopy.

I'm not sure what it would take for Mirage to upgrade TSO since I do not have a copy of AS 8015b, and I believe TSO C23d is the only one available at this time to a manufacturer either making a new rig or upgrading an old rig.

Maybe one day we can do away with the TSO process alltogether and just let manufactures do their own tests and declare what their equipment is rated for. Climbers trust gear manufacturers to tell them how strong a rope or a carabiner, or harness is without government intervention.

[Hooknswoop 19]

I'm not worried about the harness failing before the reserve or the harness or reserve failing at all for that matter, just the legalities.

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Maybe one day we can do away with the TSO process alltogether and just let manufactures do their own tests and declare what their equipment is rated for. Climbers trust gear manufacturers to tell them how strong a rope or a carabiner, or harness is without government intervention.

Sounds like a good idea. Either the FAA do a better job or not at all.

Derek

[scdrnr 0]

I agree that a PD-113R in a Mirage is not a safety concern.

What are your thoughts on the legalities? Do you think the 2 arguments I made are enough to cover a riggers ass in the unlikely event there is a legal problem?

[Hooknswoop 19]

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What are your thoughts on the legalities?

The problem is the FAA tends to follow the letter of the law regardless if it follows common sense or not. The AAD install vs. assemble fiasco comes to mind. They just don't have the knowledge about rigging and are likely to simply read them and go strictly by them. I've heard of an Inspector going to a DZ and wanting to know who had silk reserves because he had read they had a 60-day instead of a 120-re-pack cycle and he wanted to see if he could catch someone out of date.

Derek

[scdrnr 0]

The FAA usually pretty firm in their interpretations, however, they have been known to extend some leniency if you can exploit their lack of knowledge in some of the gray areas. As bureaucrats they tend to avoid conflict in areas they don't have a solid understanding of, and I don't think too many inspectors want to go out on a limb and start the enforcement process over the things like TSO compatibility with parachutes. I think most inspectors will see the TSO tag on the reserve and on the container, and it will make them feel all warm and happy inside, regardless of sub-category.

This brings up another question: Has any rigger ever faced an investigation or certificate action? Under what circumstances? Outcome?

Funny you should mention the AAD install/assemble issue - a part of the reserve system that has no TSO requirements whatsoever.....go figure.

[genitor 0]

I'm curious.

I'm assuming that this is listed on other reserve sizes as well. You mentioned PD-113R specifically. But, would this apply to other sizes as well (I'm assuming so), such as a PD-160R or PD-193R?

Is there anywhere online where you can find this information? I briefly looked at PD's website, but didn't find anything relevant. I think that looking at my own reserve's labels would be a rather expensive venture, since I just got them repacked.

Thanks!

[Hooknswoop 19]

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I'm assuming that this is listed on other reserve sizes as well.

It's only a requirement for TSO C23d to put the average peak force on the canopy. Some PDR's are under TSO C23c and some, like the 99, 106, and 113, are under d and others are under c.

I mentioned the 113 because I had one here unpacked I could look at. I don't know where else besides the label to find the avg peak force for the others.

Derek

[genitor 0]

Thanks!

[councilman24 36]

Too late and too tired to explain but the new proposed technical standard PIA TS-135, submitted to the FAA as the standard to replace the current TSO correct this issue. Yes, right now there are a number of combinations that are illegal to assemble. But some of the rigs are not required to be labeled. So this was a big issue that was a technical illegality.

We've fixed it when the new standard is adopted, but I'm too tired to try to figure it out and explain right now.

Trying to get ready for my wedding Saturday.

Later.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[Hooknswoop 19]

I looked over an un-editted copy of TS-135 last night and didn't see how it would fix the issue. It is rated to no more than 3,000 lbs force and the PD-113 has an avg peak force of more than that. The only fix I can see is to re-TSO the container or change AC-105-2C.

The problem is, now that I know, do I pack the rig?

Either Mirage didn't realize the issue, or put together illegal rigs or have something from the FAA allowing it. I would really like to know which it is, since this directly affects me.

There are a lot of reserves TSO'd under TSO C23d, and I'm sure a lot of them have peak avgerge forces above 3,000 lbs. There could be thousands of rigs that are affected.

Derek

[riggerrob 562]

... nothing illegal about mixing and matching components with different TSO's.
You merely de-rate the system to the speed and weight limits of the slowest or lightest component.

I plan to repack a PD reserve into a Mirage this morning and I will be perfectly legal under both Canadian and American regulations.

There are two reasons that harness manufacturers do not update their TSOs. First test drops are very expensive (about $800 per drop for 60+ drops).
Secondly, every time you let an auditor in, he will find something expensive to change.
Old-school (TSO C23B) manufacturers like Jump Shack, Mirage and Relative Workshop routinely test minor changes to the latest TSO standards, but avoif the hassle of subjecting themselves to new audits.

[Hooknswoop 19]

AC-105-2C says;

"The strength of the harness must always be equal to or greater than the maximum force generated by the canopy during certification tests.

(1) In a case where the harness is certificated under TSO-C23b and the canopy under TSO C23c, the maximum generated force of the harness and container; i.e, Low-Speed Category (3,000 lbs.) and Standard Category (5,000 lbs.). In this instance, no additional marking on the container is necessary. (2) In the case where the canopy is certificated under the TSO-C23b and the harness under TSO-C23c, the strength of the harness must be equal to or greater than the certificated category force of the canopy” "

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nothing illegal about mixing and matching components with different TSO's.
You merely de-rate the system to the speed and weight limits of the slowest or lightest component.

That isn't what AC-105-2C says. Even if it did, what max weight and speed do you de-rate the reserve to to be under 3,000lbs max peak force? It isn't a max weight or max speed issue, it is a max force issue. The container is rated to 3,000 lbs and the avg peak force of the reserve in testing was 3639 lbs. In this case the strength of the harness does not exceed the "maximum force generated by the canopy during certification tests"

Derek

[Hooknswoop 19]

I e-mailed Mirage and I am still waiting for a reply. Hopefully they have something that eliminates this.

Derek

[phoenixlpr 0]

I`ve heard they are in bankruptcy.

So you might not get any reply.

[kosanke 0]

as a retired airline pilot i have had many dealings with the FAA. the faa has certified aircraft with different engines. some have to be derated. in this case, the container would be the limiting factor. the manufacture received the blessings through tso and has shipped with pd's reserve. if folks choose to go outside the limitations ie: overloaded, that is the individuals issue. if a pilot chooses to exceed the derated HP, faa does not fault the manufacture or mechanic, they fault the pilot. hope this helps. Tom

[Hooknswoop 19]

It is not a matter of de-rating, it is a matter of compatability. AC-105-2C states that the reserve won't have a higher peak force thant he harness is rated to. The PD-113R has a higher peak force than the Mirage is rated to. De-rating doesn't fix it.

Derek

[riggermick 6]

Send him the PM,s I sent you, maybe that will clarify it for him. it is after all public domain.

Mick.

[Hooknswoop 19]

I talked to Mirage on the phone several weeks ago. They said they would get back to me with an answer in a couple of days after they talked to the FAA. I called and left a message which wasn't returned.

Without an answer from the factory, riggers be sure to check the avg peak force on TSO C23d reserves is less than 3,000 pounds before packing the reserve into a Mirage.

Or at least be aware that the container is not rated for a reserve that produces more than 3,000 pounds average peak force during opening and packing one is a violation of the FAR's.

Derek

[Jeffrey 0]

Derek,

AC-105-2C section 11e, which reads:

e. The strength of the harness must always be equal to or greater than the maximum force generated by the canopy during CERTIFICATION TESTING.

11e pertains to CERTIFICATION TESTING. Meaning, the harness cannot be the week link during CERTIFICATION TESTING.

Also note, AC-105-2C is not technically an FAR, it is only the FAA's interpretation or guide to the FAR's.

Jeff

[Hooknswoop 19]

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11e pertains to CERTIFICATION TESTING. Meaning, the harness cannot be the week link during CERTIFICATION TESTING.

No, it says that you cannot assemble a reserve that generates more force than the harness is rated to. That force information comes from certification tests. Where else would the force generated during deployment be measured? You couldn't know if the reserve generated more force than the harness was certified to unless you drop tested it. So to say the harnes has to be certified to more force than the reserve generates for drop tests is silly since you won't have that information until after you drop test it. If the reserve generates more force than the harness is certified to, you cannot assemble them.

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Also note, AC-105-2C is not technically an FAR, it is only the FAA's interpretation or guide to the FAR's.

Um right, which means packing a PD-113R (and others) into a Mirage is against the FAA's interpretation of the FAR's.

Derek

[riggerrob 562]

Derek,

We have never heard of Mirage harnesses (first generation, second generation or third generation) being damaged during reserve openings. Mirage harnesses are so hopelessly over-built that this is not an engineering question.

You are over-thinking this dilemma and allowing legalese to take precendence over engineering.
What is this world coming to?
I have packed dozens of PD reserves into Mirages and you are the only one complaining about legal issues.
You are the only one complaining about compatibility issues.
You are the only one complaining about compatibility issues.

[mr2mk1g 10]

I don't think he's seriously suggesting that there's actually a compatibility issue (are you?)... just that there's something of a glitch on the paperwork front meaning riggers could conceivably get caught out by a technicality.

So he's not highlighting a gear issue per say but a paperwork issue connected to gear.

[Hooknswoop 19]

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We have never heard of Mirage harnesses (first generation, second generation or third generation) being damaged during reserve openings. Mirage harnesses are so hopelessly over-built that this is not an engineering question.

Like I already said; "I'm not worried about the harness failing before the reserve or the harness or reserve failing at all for that matter, just the legalities."

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I have packed dozens of PD reserves into Mirages and you are the only one complaining about legal issues.

I don't think very many people know about it, you didn't. I am not complaining, just discussing it.

Derek

[Hooknswoop 19]

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I don't think he's seriously suggesting that there's actually a compatibility issue (are you?)... just that there's something of a glitch on the paperwork front meaning riggers could conceivably get caught out by a technicality.

So he's not highlighting a gear issue per say but a paperwork issue connected to gear.

Right, that is all I have said in this thread. Anything else just isn't there.

Derek