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RogerRamjet

Detecting AAD misrouting (Was: Fatality - Zwartberg (Belgium))

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There is no specific guidelines on what a DZ must do to make sure you comply. In theory the Pilot should inspect each rig prior to each jump. The absence of the seal would mean that there was no longer proof of the rig being packed by a rigger. Obviously things can be forged, etc. so if it LOOKS legal, the pilot is probably covered.

DZ's have implemented the procedures they individually have decided covers their and their pilot's butts. And they vary widely.



Do you think that it would be of any benefit to include written guidelines in the SIM then? If procedures vary widely would it be a good idea to provide guidelines that may protect a DZ from legal action or is it too intrusive?



What legal action are you talking about? Skydivers & pilots are either in compliance with the FAR or they are not. Additional USPA Skydiver's Information Manual guidelines will not protect anyone from legal action.
"Buttons aren't toys." - Trillian
Ken

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What legal action are you talking about? Skydivers & pilots are either in compliance with the FAR or they are not. Additional USPA Skydiver's Information Manual guidelines will not protect anyone from legal action.



If, as stated, practices and interpretations of the requirements vary widely from DZ to DZ then the requirements must not be as clear-cut as all that.

Is a DZ required to check everyone's reserve seal every time they board the plane? If they are then every DZ I've been to is at jeopardy. I didn't suggest a legal action, I just asked if better guidelines would be any benefit.
Owned by Remi #?

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Is a DZ required to check everyone's reserve seal every time they board the plane?



No that is not what the FAR's say. You should reread them or discuss this issue with Sherry if you don't understand them, she happends to be a good source of learning and is quite easy to reach and willing to provide the info.

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If they are then every DZ I've been to is at jeopardy.

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So every DZ you have been to didn't ask to see your data card or rig or ask you to sign a waver? Every Dz I have ever been to has asked to see the data card to see it in date and a lot of them, but not all, even want to see the rig and check the seal as well to see it is not broken and the symbol matches with the info on the card, most wavers also have a space where you sign that your rig is in date according to the FAR's. As a C license holder your expected to know the FAR's that pertain to you and to comply with them, this why your rig and card has to be inspected and the waver has a part to sign stating you are in compliance, with this info collected upon entering a new dz, or at your home DZ, the pilots and DZO's trust you will stay in compliance during the 120 day cycle and there for have no need to stand at the AC and check every rig on every jump, they have done their check. Most DZ's also enter your data card info in the computer and it will let them know when your 120 days is up and at that point and time they will ask again to see your card before being allowed to manifest again, this info is kept on file for many reasons, one of those would be to show the fed's during a ramp check that they checked to see your shit was in date to CYA themselves and their pilots.

***I just asked if better guidelines would be any benefit.



The info is already there and available to read and even encouraged to be read while advancing in the levels of training under the USPA training program and in BSR's located in the SIMS.
I'm surprised to see that someone who jumps at a USPA RD's DZ has such a lack of basic understanding of the FAR's and how they pertain to you. Did you not take a test to get your A,B,C or Coach rating ? Or are you one those who looks up the answers for the tests but don't file the info away? This is basic stuff covered in the A,B,C license tests as well as in the ratings course, did you not read the IRM? It is not the job of the DZO or pilot or USPA to hold your hand it is up to you to understand and comply with the FAR's that rule over you, a total lack of understand is not going to work with the fed's if you get ramp checked and are not in compliance.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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I understand that, however most newer cards have a space for the symbol and most riggers will put it on there. I do my own rigging and while visiting Skydive ATL the the manifest chick was looking over my waver and data card and rig and tried to give me some shit about my symbol not matching my seal, till I pulled out my airmans cert. so yes some dz's look for it regardless of FAR 65.131(c).
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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The SIM is not a guideline on how to operate a business. Each independent business will want to handle risk management in a different way. In fact it is NOT the DZ's responsibility but the PIC's and jumper's, although as I said I believe some inspectors have attempted or succeeded in enforcement action against a DZ or DZO. (anyone have details? I can't remember. I do know some DZ's have been reported and inspectors have come out to watch for FAR violations.) And as Stratostar outlined most try to protect themselves and pilots by some kind of inspection scheme.

I'd worry much more about DZ's that do GPS spots over and around clouds. On a day with anything but the isolated puffy it's hard to keep a whole load at least 2000' from any cloud. And we all know DZ's putting loads out over a broken or solid ceiling. This kind of violation is certainly much more dangerous than a broken seal.

I think you focusing on an issue that is between DZ's and their employee pilots.
I'm old for my age.
Terry Urban
D-8631
FAA DPRE

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In fact it is NOT the DZ's responsibility but the PIC's and jumper's, although as I said I believe some inspectors have attempted or succeeded in enforcement action against a DZ or DZO.



OK, another jumper sent me an email asking that I check this thread out and offer my thoughts, and this post is a good one to address.

Back in the day (before 2001) the FAA placed the responsibility for compliance with all regulations on the jumper and the pilot. When the FAA rewrote part 105 in 2001, the core language of many of the regulations was changed to read “No person may conduct a parachute operation…”

The words “person” and “parachute operation” are defined to include riggers, manifest workers, packers, property owners, DZ managers, and anybody else involved in a jump. For detail see my article #13 called FAA Regulation Applied at: http://theblueskyranch.com/sta/tb13.htm Thus, under current regulation responsibility for confirming the pack job is legal and in date extends to anybody connected with the DZ.

Back in the day’ when the responsibility was shared by just the jumper and pilot, there were cases where the pilot was issued an FAA violation because a skydiver had jumped with an out of date reserve. The pilots in these cases refuted the charges, claiming they had no way to inspect the rig and determine if it was legal and in date while also flying the airplane. The FAA countered that the pilot retained responsibility for compliance with all regulations, but that he could delegate the actual inspection to another responsible party, such as the drop zone manifest desk. Thus, pilots were left holding the bag for a violation that they really couldn’t control on their own.

The rewrite of the regulation in 2001 fixed this issue buy formally sharing responsibility with the DZ operation. The pilot can still be held for the violation, but so can the DZ and anybody associated with it. An inspector can now review the procedures that the DZ uses to confirm a rig is legal and find that the pilot has reasonable grounds to rely on those procedures, and thus issue a violation to the DZ instead of the pilot.

As for the requirement that the rig be sealed when jumped, there is a requirement that the rigger seal it, and everybody associated with the jump can be held responsible if the rig was packed by somebody other than the an FAA certificated rigger. The only way for a drop zone (or pilot) to assure the rig was last packed by a rigger is the official seal. If a rig has a seal, and the data card shows it is in date, then everybody associated with the jump has reasonable grounds to believe the rig is legal. Absent the seal and corresponding data card there is no such assurance, and an FAA inspector would have an easy time issuing a violation that would be upheld on appeal.

I’d say that a drop zone that doesn’t check a reserve seal can easily be held in violation if an FAA inspector finds a jumper with an out of date reserve, unsealed reserve, or a rig that otherwise doesn’t comply with part 105 (such as a US citizen jumping a non-TSO’ed rig).
.
Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

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I'm surprised to see that someone who jumps at a USPA RD's DZ has such a lack of basic understanding of the FAR's and how they pertain to you.



Them's fightin' words, "Mr Cooper" :P

Honestly... please instruct me as to where the FARs tell me I can't remove the seal?

Edit to add: And while you're at it, tell me your real name and home DZ. I've provided mine and you've chosen to use that information to suggest that I'm somehow sub-standard in the training arena because I jump at AerOhio.
Owned by Remi #?

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I'm surprised to see that someone who jumps at a USPA RD's DZ has such a lack of basic understanding of the FAR's and how they pertain to you.



I've provided mine and you've chosen to use that information to suggest that I'm somehow sub-standard in the training comprehension arena because I jump in spite of jumping at AerOhio.




You had that backwards. Fixed it for you.;)

Happy New Year!:)
"Buttons aren't toys." - Trillian
Ken

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Honestly... please instruct me as to where the FARs tell me I can't remove the seal?



14 CFR: 65.111 and 14 CFR: 65.131

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2.4.7.3 LICENSE REQUIRED
(a)No person may pack, maintain, or alter any personnel-carrying parachute intended for emergency use in connection with civil aircraft of [STATE] unless he or she holds an appropriate current license and type rating issued under this Subpart and complies with 2.4.7.10 through 2.4.7.13.
(b) Except as allowed by paragraph (c) of this subsection, no person may pack, maintain, or alter any main parachute of a dual parachute pack to be used for intentional jumping from a civil aircraft of [STATE] unless he or she has an appropriate valid license issued under this Subpart.
(c) A person who does not hold a license may pack the main parachute of a dual parachute pack that is to be used by him or her for intentional jumping.
(d)Each person who holds a parachute rigger license shall present it for inspection upon the request of the Authority or an authorised representative of the Director General Office, or any Federal, State or local law enforcement officer.
(e) The following parachute rigger licenses are issued under this part:
(1) Senior parachute rigger.
(2) Master parachute rigger.
(f) Sections 2.4.7.10 through 2.4.7.13 do not apply to parachutes packed, maintained, or altered for the use of the armed forces.
14 CFR: 65.111



If you yank your seal off the rig and then make a jump and get ramped checked upon landing and the fed's ask you where your seal is and you tell them you took it off, you will be asked to comply with section "D" of 65.111. If you can't produce a valid ticket you didn't comply with section "A" of 65.111 because you "altered" a rig and your busted, depending on what inspector you get checking you and their mood that day.

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EACH SEAL
(a)licensed parachute rigger shall have a seal with an identifying mark prescribed by the Authority, and a seal press.
(b)After packing a parachute, the parachute rigger shall seal the pack with his or her seal in accordance with the manufacturer's recommendation for that type of parachute.

14 CFR: 65.131



While not spelled out it is in this section, it implies once the seal is on the rig, the rigger is issuing a airworthy certification of the rig for 120 days. Once the seal is removed or broken the certification is now void for the pack job because the seal in no longer intact and there for it can not be sure someone other then the sealing rigger wasn't inside the pack doing work their not rated to do or as in this thread doing something to the rig to kill you.

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you've chosen to use that information to suggest that I'm somehow sub-standard in the training arena because I jump at AerOhio.



To the contrary, having worked with and attended courses put on by Sherry I'm well aware of how much detailed the info is in a course of hers and the standards she holds her staff too. Your statements imply that you don't understand the infomation and don't know where to find the information, and as a person holding a basic instructor (coach) rating you are expected to know the infomation and where to find it if you don't know it off the top of your head, you should be able to explain this info while teaching the non method specific part of the FJC and be able to direct the students you work with to this infomation within the SIMS or in the FAR's for their understanding of the rules / laws that they must comply with while conducting parachute operations. It would also imply that you may or may not do a compleat gear check of the coached students you are jumping with and would let a "student" jump a rig with a missing or broken seal because you don't seem to understand the FAR's or even where to look them up, sorry dude but it is basic stuff you should be well versed in at this stage of your jumping.

As for where I jump, you can find me in the summers @ Skydive Wayne County Richmond In. and Skydive Greensburg, Greensburg In. and at times CSC & SDC. In the winter Skydive City z-hills.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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To the contrary, having worked with and attended courses put on by Sherry I'm well aware of how much detailed the info is in a course of hers and the standards she holds her staff too. Your statements imply that you don't understand the infomation and don't know where to find the information, and as a person holding a basic instructor (coach) rating you are expected to know the infomation and where to find it if you don't know it off the top of your head, you should be able to explain this info while teaching the non method specific part of the FJC and be able to direct the students you work with to this infomation within the SIMS or in the FAR's for their understanding of the rules / laws that they must comply with while conducting parachute operations. It would also imply that you may or may not do a compleat gear check of the coached students you are jumping with and would let a "student" jump a rig with a missing or broken seal because you don't seem to understand the FAR's or even where to look them up, sorry dude but it is basic stuff you should be well versed in at this stage of your jumping.



As I've said several times I agree that checking the seal is a good idea. And I can assure you that I check for an intact seal every single time I do a gear check.

You have interpreted my questions as a challenge to the necessity of the seal. I've only been asking if the guidelines are written clearly and concisely. I'm trying to question the wording of the FARs and you're apparently hearing me say that I don't understand or agree with them. I think that if we had this discussion face to face we could probably understand each other better.

You're absolutley correct that I could go ask Sherry about her thoughts on the matter and I probably will after the holidays are over. I don't see why raising the issue here should make me somehow remiss in my training in the mean time.
Owned by Remi #?

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Holy thread drift Batman!

This has degenerated into another annoying debate about the "juvenilization" of American society.
IOW If I get hurt, someone else is at fault.

B%%%%%%%!
When you skydive/drive/drink/etc., you should be adult enough to maintain your own gear.
A pilot - at a busy DZ - does not have enough hours in a day to check every reserve seal.
Asking him to re-check seals - in the middle of the day - is worse than a waste of time. Heck! most jump pilots barely do one walk-around their airplane in the morning. During the middle of the day, they barley have time to check fluid levels.

The primary reason that the FAA holds pilots responsible - for out of date reserves - is an ancient maritime tradition perpetuated in the aviation business.
When something goes wrong on a ship, the government needs a guilty bastard/scape goat/etc. to hold responsible in the eyes of the public. Maritime courts have traditionally held ship's captains responsible for everything that goes wrong on their ships.
Remember that - in the days of sail - ships were often unable to communicate with home port/land/loved ones/etc. for months at a time.

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If you can't produce a valid ticket you didn't comply with section "A" of 65.111 because you "altered" a rig and you're busted, depending on what inspector you get checking you and their mood that day.



I don't think removing a seal is an alteration within the meaning of the FARs, as it is not an "approved" (in the FAR sense) part of the TSO configuration.

Most of the folks who are arguing that the seal must be in place for the rig to be jumped cite FAR 65.131(b), which imposes a legal requirement on the rigger. I still haven't seen anyone citing an FAR which imposes a legal requirement for the owner to keep the seal on the rig. The closest has been tombuch, who makes the argument that the presence of the seal is the easiest way to show compliance with the 120-day rule. If I had an alternate means of showing compliance with the 120-day rule, would I still need a seal on my rig? How would you know if an unsealed UK rig being jumped in the US had been packed legally and was in date?

Mark

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I don't think removing a seal is an alteration within the meaning of the FARs



To be honest I don't either, but I have seen this same type of a catch-22 wording use by an inspector, doing just as I posted in 2002, how you and I interpret the wording really don't matter in the long run, what matters is the inspectors interpretation your dealing with at the time and how they try to enforce it. The OP wanted to know where it said that, this is the best I can find, but with seeing how some inspectors are over others, I find it best to keep ones ducks in a row. I could care less if I repack your rig and you take off the seal, but it will be there when you leave the loft, I have complied, did you when removing??? I don't know it's up to their interpretation, I lean towards not, but that's my interpretation

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How would you know if an unsealed UK rig being jumped in the US had been packed legally and was in date?



You don't, only the paper work has to be in compliance to those rules and that is all you have to go on or you make them get a repack.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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How would you know if an unsealed UK rig being jumped in the US had been packed legally and was in date?



You don't, only the paper work has to be in compliance to those rules and that is all you have to go on or you make them get a repack.



>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

... and Brits require an extra layer of paperwork!
Hah!
Hah!

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While not spelled out it is in this section, it implies once the seal is on the rig, the rigger is issuing a airworthy certification of the rig for 120 days. Once the seal is removed or broken the certification is now void for the pack job because the seal in no longer intact and there for it can not be sure someone other then the sealing rigger wasn't inside the pack doing work their not rated to do or as in this thread doing something to the rig to kill you.



I think there is one big misunderstanding about the seal purpose here.
When I repack and seal a rig, that seal does not mean it's airworthy for the next 120 days.

Imagine the owner (or any other user) makes a butt slide over the runway and grinds halfway trough the legstraps.
On his/her next jump those straps fail.
Who should be held responsible?
The rigger because his seal is on and thereby declares this rig airworthy for the full 120 days, or the users for neglecting the problems they create themselves.

Sealing a rig is to identify the rigger and proving no one has been messing with it while in use.
The owner should use his/her common sense during the 120 days whether it is still save to jump it.

John J.

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While writing the way I did, yes I can see where your thinking is going, however my main point would the pack job not whole rig would remain tamper free, unless you get hold of my seal some how, your not going to be able to open up the pack job, do something (like cut a bridle/riser/lines ect) and reclose the reserve now tampered with and close with my seal again, on most rigs. Yes it is to ID the rigger, so if you bounce because someone cut your reserve cable or installed a "sleeve" on your pin and cut your aad cable, my seal may or may not be found, if it is still in place, they'll be on the way to find me. If you remove my seal walking out of the loft, anything can be done with your rig and you would/could never know it. Hope that clears up my point I was trying to make.
(I understand that is not a written in the FAR's or the reason behind the rule, but with people trying to kill others it is a good reason to keep your seal on)

riggerrob...:P you crack me up.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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While writing the way I did, yes I can see where your thinking is going, however my main point would the pack job not whole rig would remain tamper free, unless you get hold of my seal some how, your not going to be able to open up the pack job, do something (like cut a bridle/riser/lines ect) and reclose the reserve now tampered with, on most rigs.



I can access my reserve risers without opening my reserve pack job.
Owned by Remi #?

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Of course you can and so can anyone else, but putting it back with out looking funny is another story. To get mine out your going to have break the seal installed, and I'm not talking about the lead one on the reserve pin.
Next time your due for repack, pull it out enough to where it might get cut and still be hidden when replaced and then try to replace it, it can be done, but not as easy as you may think. Same could said about access to a lot of bridles depending on the rig.

Out of the known gear tampering cases to most freaky one to me was the pin sleeve installed, it took a lot of work to machine it, it was slick (well made) and could be missed very easy in a normal gear check, to install it the pin would have to have been unseated from the loop, it was found in a country I think (but not sure) they don't use seals on reserves.

I understand where you guys are comming from, I'm not going to worry about this stuff, to each their own with your rig, do as you will, I have a ticket and will do my own gear, I will continue to keep my seal press under lock and key, I will continue to inspect my and my SO's rig's on a regular basis (more then every 120 days) I will continue to look for tampering with our gear, it happend once and could happen again, but "they" will have harder time getting to the rigs, I will also continue to keep the rigs under lock and key.(even between jumps)
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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Of course you can and so can anyone else, but putting it back with out looking funny is another story. Next time your due for repack, pull it out enough to where it might get cut and still be hidden when replaced and then try to replace it, it can be done, but not as easy as you may think. Same could said about access to a lot of bridles depending on the rig.



Hey, great suggestion. My rig is in for a repack right now. I'll see if I can get to it before my rigger does.
Owned by Remi #?

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While not in the FAR's a good ref to my point can be found in Poynter's manual Vol. 1, page 452, 7.94 paragraph 3.

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The seal and "safety tie" are there, not as some mistakenly think to hold the pins in place, but for the protection of the user and the rigger. It stands guard and let's one know if the parachute has been tampered with,i.e., the thread and seal indicate that the parachute has been inspected and repacked and hasn't changed since it left the rigger.


you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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Under the heading of "useless historical trivia," seal thread was important to prevent the ripcord from falling out before springs became fashionable in pilot chutes: pre-1950s.
Ever since the MA-1 pilot chute (with spiral spring) was introduced (circa 1950?), those springs have been strong enough to prevent accidentally dropping ripcords.

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