RSL REMOVED FROM JAVELIN H/C BY RIGGERS

[livendive 8]

Y'all people are crazy! Someone please explain something to me. Let's say I, a non-certificated jumper, buy a new Javelin, PD-R, and PD Katana. I have the components shipped to my house. I remove the RSL from my rig, remove the french links from the main and reserve risers, and connect the main and reserve canopies with soft links. For some stupid reason, I then bring it to a rigger instead of packing it myself.

If you pack it, what regulation will you be breaking? Since I don't have a certificate, I have nothing at risk, and since all you're doing is an I&R, your certificate isn't at risk either.

Similarly, if I want a new lineset on my main a few hundred jumps down the road, who's going to get in trouble for violating what regulation if I order/build a lineset, do the work myself, and then pack it up and jump it myself?

Blues,
Dave

"I AM A PROFESSIONAL EXTREME ATHLETE!"
(drink Mountain Dew)

[justinb138 0]

Quote

I'm here reading my fellows riggers posts & I do not understand why it is so hard for the riggers to except
that rmoving the RSL lanyard from the Javelin is an alteration NOT approved by the mfg. Sun Path.

I think there is some confusion here. Some are arguing that removing the RSL from any rig is an alteration, not just Javelins.

[diablopilot 2]

Quote

do not let your ticket & pride to let you do rigging works that you should not do.

....followed by "Master riggers, quit letting your ego create new meanings to the FAR's."


Oh and I have relined most of my "super HP canopies", and was well within the law to do so.

A ticket means nothing without the knowledge and common sense behind it.

----------------------------------------------
You're not as good as you think you are. Seriously.

[Hooknswoop 19]

You are now talking about 2 different things and trying to combine them; what is legal and what is right.

Would you want a first time jumper jumping a Velocity 79 with zero training? I know I wouldn't. But just because it isn't smart and we (hopefully we) do not want it to happen, does not make it illegal, because it is not illegal. Arguing that because it is not a smart thing to do makes it illegal is not a valid argument.

Quote

Some riggers will say now: Mandatory SB by the mfg. it is not a must because it does not came from the FAA.

Exactly, it is not mandatory and you do not legally have to do it. This has nothing to do with what is the right thing to do.

Whether or not it is right that some that is not qualified can replace a line set on a main has nothing to do with if it is legal.

The FAR's say what they say. Trying to add what you feel is right and wrong to twist the FAR's is fallacy.

Is someone jumping a Velocity 79 on their first jump with zero training and no Instructor legal? Yes.

Is it smart? No.

Should it be legal? Probably not. That does not change the fact that it is legal.

The manufacturer does not have the authority to define an alteration, that is an FAA function.

AC-105-2C says a rigger can remove the PC form the reserve. How out-dated is that? It says you can do it, but would you?

Part 65.111 says pack, maintain or alter. It does not say, pack, light maintenance, or change how packed.

Some may say, “There is no way the FAA meant for someone with one jump to make huge alterations to their main with no experience and then go jump it”. But that is exactly what the FAR says. You have to remember that the FAA’s function is not protect skydivers from their selves, but to protect the general public from skydivers. Again, if the FAA was attempting to protect skydivers, they would have requirements for training, minimum standards for Instructors, etc. They have those for Parachutists in Command (Tandem Instructors) because they take the general public on a skydive. There are no FAA requirements for minimum performance standards, currency, or qualifications for AAFI's. If you wear your own rig, you are considered a skydiver and the FAA makes no regulations to protect you from yourself. You may jump a Velocity 79 with no training or Instructor on your first jump without breaking any FAR’s.

Derek

[diablopilot 2]

Perfect.

----------------------------------------------
You're not as good as you think you are. Seriously.

[masterrigger1 2]

Jp,
I got to come to that wind tunnel in CO.
It's got to be more educational than staying at an Holiday Inn Express for a couple of nights!

Blue ones,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[diablopilot 2]

Quote

Jp,
I got to come to that wind tunnel in CO.
It's got to be more educational than staying at an Holiday Inn Express for a couple of nights!

Blue ones,
MEL

I'll give you points for that one.....funny!

Mel, just so everyone reading this tripe is clear.....I ain't mad at cha, just don't agree with ya all the time.

----------------------------------------------
You're not as good as you think you are. Seriously.

[Hooknswoop 19]

Quote

I got to come to that wind tunnel in CO.

You'll love it. Can't wear more than just enough to prevent jumpsuit rash under your jumpsuit or you get too warm. Of course we could just open the louvers a bit and cool things off.

You are always welcome out here, you make me think
Derek

[RIGGER 0]

You can play with your new rig without having a rigger ticket all time you or others are not taking it into an aircraft. You are not allowed by law to Ass.I&R the TSO'd parts of the system & Ass. the main. By the way what about the AAD did you put it in place too ?

If you did all you said & go to a rigger for I&R only you totally wrong. The rigger in charge MUST check all items you used to fine out if all are approved by the h/c or the canopies mfg., set back the RSL in place after all is well & no damage to the riser from the hook velcro when you moved the RSL or any kind of damage, the rigger will Assemble I&R the system.

When you deal with a rig arriving in after being done by others you the rigger in charge sign for recertification of the TSO'd system including Assembly that must be checked if done by others !!!

Safe Rigging !!!

[diablopilot 2]

Quote

Quote

I got to come to that wind tunnel in CO.

You'll love it. Can't wear more than just enough to prevent jumpsuit rash under your jum..
Derek

What's that?

----------------------------------------------
You're not as good as you think you are. Seriously.

[livendive 8]

Quote

You can play with your new rig without having a rigger ticket all time you or others are not taking it into an aircraft. You are not allowed by law to Ass.I&R the TSO'd parts of the system & Ass. the main. By the way what about the AAD did you put it in place too ?

If you did all you said & go to a rigger for I&R only you totally wrong. The rigger in charge MUST check all items you used to fine out if all are approved by the h/c or the canopies mfg., set back the RSL in place after all is well & no damage to the riser from the hook velcro when you moved the RSL or any kind of damage, the rigger will Assemble I&R the system.

When you deal with a rig arriving in after being done by others you the rigger in charge sign for recertification of the TSO'd system including Assembly that must be checked if done by others !!!

Safe Rigging !!!

Is that in something other than the FARs? Because I was unable to find regulations confirming your opinion. The closest I see is 65.129(e), which states:

Quote

No certificated parachute rigger may--
...Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute;

Since the rigger in this situation would not be maintaining or altering the equipment (assuming I also installed closing loops of proper length), just packing it, the question that arises is whether packing the reserve (or main) with soft links or without an RSL installed deviates from procedures approved by the manufacturer of the parachute. Or at least that's how I read it. Please let me know if there's a regulation that I'm just not seeing.

As for the AAD, I didn't bother buying or installing one for this hypothetical scenario.

Blues,
Dave

"I AM A PROFESSIONAL EXTREME ATHLETE!"
(drink Mountain Dew)

[deathtrap 0]

Shlomo, what is your take on this:

Quote

Quote

that affects the strength or
operation of the auxiliary parachute, including the harness,
must be regarded as an alteration of the auxiliary parachute
and handled accordingly.

So, by removing the RSL LANYARD you're affecting the operation of the auxialiary parachute? If you think so, then releasing the snap shackle has the same effect, so that would be an alteration also.

I'm curious, since you say that if the jumper doesn't want to use the RSL, they should just disconnect it. This would seem to contradict the whole reason for this thread in the first place, other than the poll.

I think your advice about being an "Aviation Rigger" is good, but there are many things that are not black and white, and I think this is one of them.

[mjosparky 3]

Quote

To show what I mean here, lets change the topic from an RSL to a BOC.
Lets say a rig left out of factory "A" with a ROL deployment pouch.
A end user now wants a BOC pouch installed.
Manufacturer "A" cannot issue a statement saying moving the location of the pouch is not an alteration, when the FAA says it is.
Also on that same note, Manufacturer "A" cannot issue a statement saying that a Senior rigger could move it. As you know only a master rigger can do it according to the FAA.
There are cases where this has happened.
It doesn't mean it it is legal

A ROL change to a BOC is changing the placement of the Main deployment device. It in no way "affects the strength or operation of the auxiliary parachute, including the harness." So it seen that it is not an alteration to an approved parachute system. According to AC-105-2C approval is not needed for a method of altering a main.

a. An alteration to an approved parachute system used for
intentional jumping must be done in accordance with approved
manuals and specifications and only by those with specific
authorization to perform that alteration. Specific approval is
not needed for the method of altering a main parachute. A person
seeking authorization to alter an approved parachute system
should proceed as follows:

Since Part 65 specifically allows the next person jumping a main to alter it, it would seem that anyone could change out an ROL for a BOC.

(b) No person may pack, 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—

(3) Is the person making the next parachute jump with that parachute in accordance with §105.43(a) of this chapter; or

My idea of a fair fight is clubbing baby seals

[masterrigger1 2]

same here!
Mel

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

Sparky,
No debates-- It's the weekend FCOL

Besides the BOC Thing is spelled out in the AC-105-2C-( I think) It also is an exact test question and it also is a recommended procedure in the PTS for the master's test.

Now go drink a beer on me- I'll pay for it when I get back out there next month!


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[JerryBaumchen 1,047]

This has been an interesting thread to follow. Seems to be another of those flame wars that are continually cropping up here on good old dz.com. Where's my asbestos suit when I need it.

At first I did not want to have anything to do with this discussion (Did not want to stick my toes into those roiling waters.). But maybe I can offer some thoughts to all of you. And, maybe I cannot. Decide for yourselves.

Please remember, these are my thoughts and have no force of law or regulation. For the most part, they are based upon my personal experience.

I get to wear two hats; that of a rigger in the field (been one for over 40 yrs) and that of a TSO-authorization holder/mfr (been one of those since '79). I obtained my TSO-authorizations under C23b; since then C23c has come and gone and C23d is now in effect; with a new one on the horizon. All three are different in many respects, as will be the next version.

The riggers hat) If I were to call up Sunpath and someone other than the cute, young receptionist were to tell me not to remove the RSL because that is not allowed, then that is what I would do. If the customer then went to the next rigger in line and he romoved it, I'm OK with that; I did not do it. I look at this just like the guy who says he will repack a pop-top rig, his choice. I also would not repack that Javelin once the RSL has been removed; my choice.

Although, over the years I have done a whole lot of 'modifications' to a whole lot of parachute equipment. Heck, back in the Winter/Fall of '66-'67 I designed, built, tested and installed on my rig, what I believe was the world's first AAD for a piggyback reserve container. Now that was a very substantial modification to my X-BO reserve container. Did I go to the mfr or the fed's for approval; no, I just did it? However, in the attorney-laden world in which we live today, there is a lot of that old 'rigging' that I would not do again.

The mfr's hat) Back in '79 when I applied for my TSO-authorizations, I had to submit a QA Manual (the only thing that the FAA really approves), Test Reports showing that my equipment/product/component(s) had met the req'ments of NAS 804 (the referenced document), and the 'specifications' (for most of us, that would be the drawings of just what we were seeking TSO-authorization for, the equipment/product/component).

Now then, it is this 'specification' thing that is what we do not know much about. In my case, I consider my submittals to be proprietary information. I would think that most mfr's feel the same way. If you want to know what I submitted, then buy my business; it is for sale. Yup, shameless advertising plug here.

I chose to go the 'minimalist' route on my '
specifications.' I submitted what I felt was the absolute minimum amount of information on the drawings that I thought that I could get passed the FAA people (do not give them anymore information than you have to is my thinking). They do not have the experience to know whether what you have submitted is sufficient or not.

If you look at the TSO marking (that means label to most of us) on a Vector III reserve container it says something about 'Wonderhog' and 'TSO C23b' (I'm going from memory here because I do not have one handy to look at). Today, the V-III (I think) somes with a 'kinda different looking' reserve pilot chute, a reserve d-bag, a Skyhook, pockets-etc for an electronic AAD, a 3-Ring system, stainless steel hardware, and so on. Now think about the original Wonderhog; it did not come with a reserve pilot chute (most riggers just put MA-1's in the reserve container), it was set-up for a round reserve canopy (remember the bungee hesitator loop that the bridle folded into?), it was a 2-pin container, and it had Capewells. In the eyes of the FAA, the V-III is still just an original Wonderhog, with some 'minor changes.' Just from looking at an old Wonderhog reserve container I would guess that the original submittal was rather 'minimalist' also. There just wasn't much there to actually detail; a very simple, minimal container (Roger RamJet, where are you when we need you?).

This evolvement of the configuration of parachute equipment comes under the Minor Change section of Part 21; in engineering we call 'creeping design changes.' There is almost no industry in which this is not a common occurrence.

I once had a rather lengthy conversation with John Sherman of the Jump Shack and he is adamant that the only person who can determine just what is a Minor Change is the original designer. And not the FAA. I like that perspective.

About now you're thinking 'Just where is this guy going with this?' Well, it has to do with those 'specifications' and what we do not know about them. I simply do not know if the Javelin RSL is included in those 'specifications' that have been submitted to the FAA or if it is not (there are numerous regional Aircraft Certification Offices [ACO's] around the country; I'm under the one located in Renton, Washington, mfrs in Florida come under the one located near Atlanta). If the RSL is not included in the 'specifications', then (IMO) it is not a part of the 'approved parachute' as referenced wherever.

I can assure you (once again, IMO) that when push comes to shove, the only thing the FAA will be concerned about are the things that are included in those nasty old 'specifications.' I think that we can all agree, somewhat, that the FAA folks to not know or understand parachutes (in 26 yrs I've only had one ACO Mgr admit that and he was the best one I have ever worked with). However, they very much do understand documentation. They might not know what it means but they know what you have sent to them. If you deviate from that, they have a 'gotcha.' Most of them that I've met (but not all) like to find those 'gotchas.'

Earlier versions of the TSO made no mention of an RSL. This leads me to believe that including it in the 'specifications' might not be required. I say 'might not be required' because, in my experience, the way each ACO sees things is quite different. Also, when I think about how the Javelin RSL is designed and installed, it seems to me that the only interaction of the RSL with anything that is part of the container and/or harness is the installation of the little RW-4 ring on the flap that the ripcord cable goes across & the Velcro that is added to the back of a reserve riser. I would think that they could easily argue that the ring around the ripcord has no effect on the manual operation of the system and therefore does not need to be included in the 'specifications.' However, again I do not know what all is detailed in their 'specifications.'

I have a draft copy of the document that the PIA committee has come up with for TSO C23e (the one that is on the horizon) and it says 'If a reserve static line is part . . . ' This leads me to think that the RSL will have to be included and detailed in the 'specifications' being submitted under C23e when it comes into effect. Only time will tell.

What I am trying to say is this, when any discussion of modifications/alterations to an 'approved parachute' are undertaken, then it is important to know just what is this 'approved parachute.' And for most riggers in the field, they really do not know. Considering that, I would go by what the mfr tells me.

Now back to our Javelin RSL) If it is a part of the 'specifications' then altering it definitely (and once again, IMO) will come under the rules and regs of the FAA; however those rules and regs get interpreted. If it is not a part of the 'specifications' then I would think (yes, one more IMO) that a field rigger could remove it without concern (this is not a pro or con position on any safety aspect of an RSL; that's a completely different issue).

The crux of the whole thing is that I simply do not know if the Javelin RSL is a part of their TSO-authorization or not. If Sunpath tells me not to remove it, then that is what I will do. I do not have enough information (those nasty old 'specifications') to do otherwise.

So have I made you more confused? I hope not.

[mjosparky 3]

Veyy good post Jerry. I think you have brought up something none of us had given thought to.

Sparky

My idea of a fair fight is clubbing baby seals

[masterrig 1]

Thank you, Mr. Baumchen, for what you have written. I think, you've clarified things quite well and made a substantial point. I've always felt that, the manufacturer has the last word on their product and to me, what they say goes. After all, I could not see where, any manufacturer would want to stick their chin out, knowing our litigous society. Thank you, again.


Chuck

[marinho 0]

Hi Jerry,
Thank you for all this professional info. It's definitely very educational to read your post.
Any time you come to the Carolinas, please stop by at our shop. It'll be a pleasure to have a beer with you!
Cheers,(clapping my hands)

Gus Marinho

[Hooknswoop 19]

SO, what you are saying is that whether or not it is an alteration depends on if it is listed in specifications that riggers do not have access to? A manufacturer could simply say that it is an alteration?

Doesn't AC-105-2C give the authority for a rigger to determine compatability of TSO'd components? One manufacturer has told me that AC-105-2C is not an FAR and only guidence. This is because if it was law, then there are some reserves TSO'd under C-23d that could not be assembgled with some containers assembled under TSO-C23b.

Derek

[packertom 0]

come on guys... I can't believe that this thing is still alive.. let's sum this up in a few sentences...

as a rigger you are REQUIRED to MAINTAIN THE SYSTEM IN ACCORDANCE WITH THE MANUFACTURERS (in this case Sunpath) RECOMMENDATIONS... the manufacturer states that in this case and only this case, the RSL is STANDARD equipment and RECOMMENDS that the RSL not be REMOVED-- you can still DISCONNECT the RSL (that is what the snap shackle is designed for) if the manufacturer recommends that you not remove an item from their rig, you are required to adhere to their guidance... it's pretty much that simple... trust me on this, I've been through this nut roll specifically. if you want a javelin, fine, great rig, but it's going to have an RSL on it, if you don't want an RSL attached to your rig, fine... buy another brand that doesn't recommend that the RSL not be removed or offers it as an OPTION, not as STANDARD equipment... if you remove the RSL on a javelin, please be warned that you may be called to the carpet by your friendly local FSDO for making an alteration to the TSO'd components of the system... I know for a FACT that when the FSDO calls Sunpath with this question, that is what they will say... as stated previously, I've been through this... trust me on this, I'm not bullshitting you here. We were specifically told by the FSDO that if he found a rig that we had removed the RSL from he would take great joy in violating the rigger in question.

Tom

[email protected]
www.applieddeceleration.com

[masterrigger1 2]

Jerry,
I am going to shorten the response to your post, which was very good in some points.

While I am not currently a TSO holder, I hope to be soon and also have been involved with several H/C and reserve parachutes in the past years.

But all of that has nothing to do with what we are talking about; alterations to H/C containers and other parachute equipment after they leave the manufacturer.

Talking about the past, i.e.,

Quote

"I have done a whole lot of 'modifications' to a whole lot of parachute equipment. Heck, back in the Winter/Fall of '66-'67 I designed, built, tested and installed on my rig, what I believe was the world's first AAD for a piggyback reserve container. Now that was a very substantial modification to my X-BO reserve container. Did I go to the mfr or the fed's for approval; no, I just did it?

It does not mean it was legal. It just means you did not get caught and/or no one really cared. That is, if the regulations where the same "back in the day".

Today's definition of an alteration is spelled out pretty clearly.
To sum up the way it is written; basically if you change the H/C from the way in which it was manufactured, it is an alteration.

Therefore you, the rigger, are now required to follow the FAA procedures as such.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[JerryBaumchen 1,047]

Hi Derek,

I did not use the word 'alteration.' What I am referring to is that which has FAA TSO-authorization.

When I think about the current status of parachute equipment mfd in this country today (yup, I include Honduras in this definition) I see little need to 'alter' any of the equipment.

Consider that Vector III that I mentioned in my rather long post. You can get with step-ins or with snaps, with a stainless steel reserve ripcord or a pud, with a main that is activated by throw-out, pull-out or ripcord, a reserve setup with no RSL, with an RSL or with a Skyhook, it comes setup for an electronic AAD but you choose to have the AAD or not, etc, etc. You can get a main canopy in many sizes and types (square - elliptical - accuracy - etc), and just about the same with your reserve canopy.\

What is there to alter?

I do see a continuing need to maintain the equipment.

I will not try to define what AC 105 says, that is for the federal gov't. to do; it is their document. I agree that an FAR trumps an AC any day. However, I do agree that you can get two different feds to give you completely different interpretations of an AC. AC = Advisory Confuser.

I think that the PIA should take a much stronger stand and be a central voice for the rigging community when these 'interpretations' cause so much concern out in the field. I think it would be nice if a field rigger could submit his questions to the PIA and they would get a defining response from the FAA. I know it would be time consuming but at least some confusion would, hopefully, disappear.

I feel very strongly that the vast majority of riggers in the field really only want to do what is correct and safe. They do not look for ways to reduce the reliability or airworthiness of the equipment.

I also wish that the FAA could get out of business of regulating parachutes for sport use. But that's a totally different issue.

This may or may not have answered your questions, but those are my thoughts.

Jerry

PS) I've lurking around this board for 6-8 months and I agree almost 100% with all of your posts on rigging, the regs, etc. Keep up the good work.

[JerryBaumchen 1,047]

Hi Mark,

You're correct; I did not get caught.

I became a Master Rigger in '71 and operated under the idea that a MR can change parachutes anyhow he wanted. I now feel that the regs are not definitive.

Later I became concerned about being 'legal.' Now whenever I want to alter something (and it has been years because I find no need to do so today) I develop a procedure, run it over to my FSDO and get them to give me a field approval; I've never been turned down. I probably have a dozen or more of them; everything from cutting holes into rounds for steerability to installing a grommet in the top of a Mini-Grabber pilot chute.

I do this because I want documentation, not a verbal 'thought' from the FAA. It is called CYA.

It is how I do things and I will not condemn someone who takes a different approach to their rigging.

So you want to get into the game, huh? Give me a call sometime.

Jerry

[jheadley 0]

I found this thread from a year ago and thought it'd be worth bumping since the topic came up again.