0
RIGGER

RSL REMOVED FROM JAVELIN H/C BY RIGGERS

Recommended Posts

Quote

The definition of an alteration to a parachute or parachute system, as defined by the FAA, is a change from the original configuration from which it was manufactured.

see below...

B. Any change to the configuration, method of
operation, or method of packing the main parachute, up to
and including the main canopy attachment links or the male
end of the quick release fittings, is a main pack alteration.
Any main parachute alteration 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.



What?? So it's an alteration if I swap my French links for soft links? Or if I take a student rig and re-configure it from S/L to ripcord operation or hand-deploy? Or if I install new main risers?

Share this post


Link to post
Share on other sites
Sparky,
The comment about main parachutes not being regulated cannnot be true because:
1. 65.111 TELLS you who can pack it before the next jump. No one that I know disputes that.
So, therefore it is regulated.

2. To further say main parachutes are regulated, there is also a regulation stating that the main has to be packed within 120 days, just like a reserve.

§ 105.43 Use of single-harness, dual-parachute systems.

No person may conduct a parachute operation using a single-harness, dual-parachute system, and no pilot in command of an aircraft may allow any person to conduct a parachute operation from that aircraft using a single-harness, dual-parachute system, unless that system has at least one main parachute, one approved reserve parachute, and one approved single person harness and container that are packed as follows:

(a) The main parachute must have been packed within 120 days before the date of its use of a certificated parachute rigger, the person making the next jump with that parachute, or a non-certificated person under the direct supervision of a certification parachute rigger.



MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

Share this post


Link to post
Share on other sites
Well... is it then safe to say that Main Parachutes have very few regulations? As in... If I want to make a trip past the fabric store... hardware store... and then home to my sewing machine... sew myself up a main of my own making... put it on some risers... pack it up (myself) and then go jump it (myself)... within the next 120 days... I'm not busting any regulation on Mains.
:P

Anyway, I think that when folks think about "regulations" on parachutes, they think about TSO requirements and such that are placed on Reserves and Harness Container systems... which, Mains do not have to meet; ergo, not subject to those requlations.

Share this post


Link to post
Share on other sites
Quote


What?? So it's an alteration if I swap my French links for soft links? Or if I take a student rig and re-configure it from S/L to ripcord operation or hand-deploy? Or if I install new main risers?



Only if you are doing it in the USA.
Since you are a foreigner in Thailand, no would probably be the answer!

Cheers,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

Share this post


Link to post
Share on other sites
Quote


Well... is it then safe to say that Main Parachutes have very few regulations? As in... If I want to make a trip past the fabric store... hardware store... and then home to my sewing machine... sew myself up a main of my own making... put it on some risers... pack it up (myself) and then go jump it (myself)... within the next 120 days... I'm not busting any regulation on Mains.




As the old saying goes, " you can build it(main parachute), but you can not work on it!"

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

Share this post


Link to post
Share on other sites
Quote

if I take a student rig and re-configure it from S/L to ripcord operation or hand-deploy?




Well... I was always told those things had to be done by a rigger. Kind of like some things being done on an aircraft have to be done by an aircraft mechanic and duely noted in the log-books... e.g. removing a normal door and replacing it with an in-flight door of an approved type on an aircraft certified for flight without the door installed.


Quote

Or if I install new main risers?



Well... I've done that myself... but before I got my riggers ticket... I always had a rigger look at it when I was done... that's my story and I'm stickin' to it!
;)

Share this post


Link to post
Share on other sites
Quote


As the old saying goes, " you can build it(main parachute), but you can not work on it!"

MEL



Okay, educate me please here MEL... what says what where that leads you to believe "anyone" can't sew a patch on a Main, R&R a line kit, etc... it has to be a rigger? ... if that's what you're saying?

Traditionally, I've always believed that its riggers that do such work on Mains because its us that have the skills to do so... but I never thought there were actual regulations saying it had to be a rigger working on a Main like it has to be on a Reserve, Harness/Container.

Share this post


Link to post
Share on other sites
Oh,
I called them alright. You should too. If you are a senior rigger and you remove the RSL from the system that would be in violation of the priveleges of your ticket. Dave at Sunpath says that is an alteration. If you are a Master rigger and you remove it, you are making an alteration which is unapproved by the manufacturer. Call him right now and ask. Their website says to call with rigging questions and they ARE the manufacturer. Who do you think the lawyers are going to listen to? You???? The RSL has a simple clasp, allowing the user to unhook it....geeeezzz!
"It's very important at this point that you don't simply become a passenger." Flight instructor Dennis Anderson speaking about life and crosswind landings.



Share this post


Link to post
Share on other sites
If an RSL is by design made to be disabled by even the end user and they either take off the RSL or have you do it as a rigger, how is that an alteration? By definition an alteration has to affect function. Taking off the Velcro of a disabled RSL alters nothing since there is no change in function. Just because someone says that it is does not necessarily make it so.

Just some thoughts
Time and pressure will always show you who a person really is!

Share this post


Link to post
Share on other sites
The Manufacturer has stated that removal is an alteration. A senior rigger cannot alter any portion of the system in accordance with his ticket. A master might remove it but it will be an unapproved alteration. For clarification CALL the manufacturer. When I took my riggers course and the FAA written they gave us several sources of information. The Manufacturer is first on the list. Sorry, but they did not mention that I might get it on DZ.com.. While it is fun to read and debate here, and I do, in cases of rigging questions pertaining to reserves and containers, it is best to consult the manufacturer and follow their reccomendations. The FAA and the courts are going to use the manufacturers interpretation of the information, even though I can clearly see that most here want it to be their own interpretation that wins. The debate ends with what the manufacturer says. Call them, they are clear, concise and always glad to answer any and all questions.
"It's very important at this point that you don't simply become a passenger." Flight instructor Dennis Anderson speaking about life and crosswind landings.



Share this post


Link to post
Share on other sites
TB,
65.111 covers packing, maintaining and who may alter a main parachute.

Let's cover each seperately.

Packing- I think we all agree as to what , how, and why it reads the way it does.

Maintain - light maintenance applies here. Inspection for rips, tears, cleaning,etc. General upkeep alot like a car or airplane.
Note : airplane owners are allowed to do things like change oil, grease wheel bearings, and general light maintenance.

You get the picture!

Alter- This is referenced and defined in the Inspector's handbook as a change in the way a parachute is packed.
Not in a modification sense.
I posted that info a few post back.

As far as a small patch that would not affect airwothiness; I believe the owner could do that.
I have not looked at that though.

Relines--No - AC - 105 - 2C spells that out for you.
It even gives an example of such.
It is considered a major repair.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

Share this post


Link to post
Share on other sites
According to CSPA, sewing machines mark the upper limit of a Rigger A's skills. In other words, Rigger As are not supposed to touch sewing machines.
Since un-rated skydivers are lower on the totem pole than Rigger As, by definition, they are not allowed to sew on parachutes (i.e. repair fabric or replace lines).

Finally, since those of us who make our own mains (I sewed together a couple of Para-Kits back in the 1980s) are such a TINY percentage (maybe 1%) of the skydiving population, I have no idea why we are wasting so much time on this thread drift.

Share this post


Link to post
Share on other sites
Quote

The Manufacturer has stated that removal is an alteration.

The manufacturer has also said the you are allowed to alter and/or disable the function of the RSL and they even provided a quick release shackle and directions to make it easier.:PThis issue could clearly have been prevented in this case if the manufacture had put the pile on the container side.
Time and pressure will always show you who a person really is!

Share this post


Link to post
Share on other sites
Quote

TB,
65.111 covers packing, maintaining and who may alter a main parachute.

Let's cover each seperately.

Packing- I think we all agree as to what , how, and why it reads the way it does.

Maintain - light maintenance applies here. Inspection for rips, tears, cleaning,etc. General upkeep alot like a car or airplane.
Note : airplane owners are allowed to do things like change oil, grease wheel bearings, and general light maintenance.

You get the picture!

Alter- This is referenced and defined in the Inspector's handbook as a change in the way a parachute is packed.
Not in a modification sense.
I posted that info a few post back.

As far as a small patch that would not affect airwothiness; I believe the owner could do that.
I have not looked at that though.

Relines--No - AC - 105 - 2C spells that out for you.
It even gives an example of such.
It is considered a major repair.


MEL




MEL... maybe we're saying the same thing... maybe we're not, but I am enjoying the converstation because I'm learning some things... however... you pointed at FAR Part 65.111... an excerpt I cut here:

Quote


From FAR Part 65.111:
(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--
(1) Has an appropriate current certificate issued under this
subpart;
(2) Is under the supervision of a current certificated parachute
rigger;
(3) Is the person making the next parachute jump with that parachute
in accordance with Sec. 105.43(a) of this chapter; or...



The way I take (3), above... (my words now) a jumper "may pack, maintain, or alter any main parachute" to their hearts desire as so long as they're the only person jumping it... and not be in violation of the FARs. Okay, maybe a bit if a nit, but still.

I'm not disagreeing with you on what makes a repair a Major Repair... and will read more on AC 105-2C... but cannot see how a person is violating the FARs, if that (non-rigger) person making a Major repair on a MAIN is the ONLY person jumping that Main... as to the wisdom of doing so... that's a different story.
;)

Share this post


Link to post
Share on other sites
Quote


The way I take (3), above... (my words now) a jumper "may pack, maintain, or alter any main parachute" to their hearts desire as so long as they're the only person jumping it... and not be in violation of the FARs. Okay, maybe a bit if a nit, but still.



You should understand it really soon.

The Office of Enforcement and Compliance called me the last two days regarding the above.They are the ones that give out interpertations.
Hopefully, there will be a written resolution to it all very soon!

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

Share this post


Link to post
Share on other sites
Quote

Let's cover each seperately.

Packing- I think we all agree as to what , how, and why it reads the way it does.



Agreed.

Quote

Maintain - light maintenance applies here. Inspection for rips, tears, cleaning,etc. General upkeep alot like a car or airplane.
Note : airplane owners are allowed to do things like change oil, grease wheel bearings, and general light maintenance.

You get the picture!



It says "maintain", not "light maintenance". The FAR says what it says, not what you want it to say.

Quote

Alter- This is referenced and defined in the Inspector's handbook as a change in the way a parachute is packed.
Not in a modification sense.
I posted that info a few post back.



It says "alter", not "change [snip] the way a parachute is packed." Again, the FAR says what it says, not what you want it to say. Changing the way a parachute is packed is considered an alteration, so if you are saying that the FAR says the jumper jumping the main next may change the way it is packed, then you are saying they may alter it. Limiting the alterations allowed to changing how it is packed is not spelled out in the FAR, only in your interpretation of it.

If you read into an FAR, you can make any FAR say anything you want. But, as written, it says:

"(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 --
(1) Has an appropriate current certificate issued under this subpart;
(2) Is under the supervision of a current certificated parachute rigger;
(3) Is the person making the next parachute jump with that parachute in accordance with §105.43(a) of this chapter; or
(4) Is the parachutist in command making the next parachute jump with that parachute in a tandem parachute operation conducted under §105.45(b)(1) of this chapter"

If the FAA didn't mean to write it the way they did, they should change or clarify it. I will follow the letter of the law, as written. In the mean time the FAR says what it says and the next person jumping it may alter it all they want and those alterations are not limited to changing how it is packed.

WE could discuss how much the FAR's make sense, but, in relation to skydiving, they don't make a whole lot of sense since some one with zero training or instruction can legally jump with no helmet, AAD, altimeter using a Velocity 79 as a main and a PD-99R as a reserve on their first skydive without violating an FAR. Just because it is legal does make it a good idea.

As for a manufacturer saying what is and what isn't legal, that is not their function, nor do they have the authority, only the FAA does. When tandems went mainstream and the gear become regulated by the FAR's as sport gear, compatability became an assembling rigger function. One manufacturer attempted to declare that only their main was legal to be packed into their container. They don't have the authority to do that.

Derek

Share this post


Link to post
Share on other sites
No implication meant or needed. You simply want it your way. Call ANY manufacturer and ask them if it is an alteration to remove, NOT DISCONNECT, to remove an RSL from a container which was manufactured with the RSL. Do you have a phone? The answer is always the same. Try it and see. I did!
"It's very important at this point that you don't simply become a passenger." Flight instructor Dennis Anderson speaking about life and crosswind landings.



Share this post


Link to post
Share on other sites
No I don't just want it "my way".


In 5 years of selling gear for 2 major gear dealers I have talked to more than a few manufacturers and I assure you more than one has approved not using the RSL shipped with the rig.

Picture this if you can. A H/C is shipped unassembled. By your logic the person who assembles it must be a master rigger to INSTALL the RSL in the first place.
----------------------------------------------
You're not as good as you think you are. Seriously.

Share this post


Link to post
Share on other sites
Quote

Quote


The way I take (3), above... (my words now) a jumper "may pack, maintain, or alter any main parachute" to their hearts desire as so long as they're the only person jumping it... and not be in violation of the FARs. Okay, maybe a bit if a nit, but still.



You should understand it really soon.

The Office of Enforcement and Compliance called me the last two days regarding the above.They are the ones that give out interpertations.
Hopefully, there will be a written resolution to it all very soon!

MEL



*slaps forehead*

I'll try this one more time and then I'm gonna bail on this discussion depending on what comes back...

MEL... what do you mean by your last post? You narked me out to the FAA?? ... but seriously.

When FAR 65.111 says that the next person to jump a Main Parachute may pack, maintain, or alter said parachute... how is it you believe doing by so a person would be a violation of the FARs as long as that same person is the only person to ever jump that main?

If the FAA is trying to clarify this in some manner... that scares me... I wish they'd leave well enough alone before they muck it up anymore.

Share this post


Link to post
Share on other sites
WHAT?????????????????????????? By YOUR logic anyone can just willy-nilly cut stuff off a rig and hand them out as if nobody cared. I guess you follow YOUR little rules when and if you want and I'll just call the manufacturer. Thanks for playing. Like I said before, it's fun to argue here but the lawyers and the FAA are going to use the manufacturers interpretation of alterations and I wish you well with your home brewed rule book. See ya!
"It's very important at this point that you don't simply become a passenger." Flight instructor Dennis Anderson speaking about life and crosswind landings.



Share this post


Link to post
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

0