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packertom

JAVELIN RSL... IMPORTANT, MUST READ

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I just got off the phone with Dave Singer from SunPath to get clarification on this issue. What I was told by him is this is not a SunPath issue but an issue with AC105-2C. The question of Alteration and modification is alittle unclear. His stance was that removing any component of the RSL system is a alteration. Basically there are 2 approved Javelin configurations on file with the FAA. Javelins produced in 1989 and earlier(Before RSL) and Javelins produced after 1989(RSL installed). By removing a RSL component you are altering the newer FAA approved system to match the older FAA approved system. He stated that because the paperwork is already on file with the FAA for a Javelin without an RSL then nothing other than a master riggers signature is needed. Now if a master rigger wanted to modify an existing FAA approved system say for example add dive loops to reserve risers then FAA or manufacturer approval would be needed and the proper paperwork would have to be filed. This holds true for any container out there not just the Javelin.
Hope this helps clear things up, I know after talking to Dave it cleared up things for me.

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I was told by the FSDO FAA inspector, I need to reinstall the RSL and take it to the master rigger to have him remove it



I don't think your FAA inspector knows what he's asking. Installing the RSL may be a major repair. To be sure you are installing it correctly, you will need approved materials and drawings.

OTOH, I wouldn't go back to that particular inspector with that question, since the answer is likely to be that the master rigger needs to install it in order to remove it.

Crazy, isn't it?

Mark

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Basically there are 2 approved Javelin configurations on file with the FAA. Javelins produced in 1989 and earlier(Before RSL) and Javelins produced after 1989(RSL installed). By removing a RSL component you are altering the newer FAA approved system to match the older FAA approved system. He stated that because the paperwork is already on file with the FAA for a Javelin without an RSL then nothing other than a master riggers signature is needed.



I'm not sure that solves the problem. Earlier Javelins were approved under C-23c, newer ones under C-23d.

Mark

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good point on the difference between different TSO's ... here's the big question....

if your rig was manufactured prior to 1989 is it immune to this ruling? if that is true it would be a big help for a lot of jumpers... sunpath's letter is pretty clear, but I think they need to clarify if some of their rigs, like one's that never had an RSL installed are not covered by this recommendation.

I'm not going to call sunpath, I'm sure that their phones have been busy enough and I seem to have stirred up a large enough hornet's nest already...

one other note... for some reason, we've been getting an attitude from some that we are responsible for this thing... nope, we just asked for a clarification in writing and this was it... instead of pointing fingers riggers, why not say thanks that we helped in getting a ruling on this thing so that riggers, packers and pilots know where they stand now instead of finding out where they are in a civil court... I honestly am having trouble understanding ignorant people who are hell-bent on shooting the messenger... remember, we dont work for sunpath, we just asked for clarification on an important issue that honestly if you'd thought about it a little more might have wanted to know on your own to protect yourselves... just my .2 cents worth of venting.

Tom
[email protected]
www.velocitysportswear.com
What's YOUR Zombie Plan?

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I don't want to bother Dave or Derek about this, so I'll ask you riggers out there.
I'm sure their phone is ringing off the hook.

Now Sunpath just said that they will be putting in a SkyHook on their new rigs.
An RSL and Collin's lanyard are required in order for the SkyHook to work.
Does that need yet another FAA TSO?

What I don't get is why you can't have a Sunpath rig with or without an RSL on rigs that do not have a SkyHook.
And
With a SkyHook equipped rig that the RSL is mandatory.

Somehow I think the Skyhook mod is the driving factor here.
But these issues did not come up with RWS/new name.

It's also my understanding that with a Skyhook equipped rig the RSL has to be on the right riser, not left. RWS rigs have always had the RSL on the right riser. Wouldn't that require a new TSO from Sunpath (or any mfg that wants to add a SkyHook) too?

.
.
Make It Happen
Parachute History
DiveMaker

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Obviously if it's just a signature it's not a big deal.



It's not a big deal if you can find a (local) master rigger who's willing to sign off the alteration. If master riggers on the whole decide that they don't want to take on the liability for this, then senior riggers (and owners) may find themselves in a bind.

Amy

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You're only allowed to disconnect the RSL shackle in case of emergency, meaning crw dogs and camera people are screwed?!? Or, hopefully, just won't follow this reg.

Seems like totally removing the RSL may be easier than just disconnecting it for certain jumps which is screwed up :S



I would bet you that the crwdogs and camera jumpers are going to just say to hell with sunpath and disconnect their rsls in the plane before jumping. :P
"Mediocre people don't like high achievers, and high achievers don't like mediocre people." - SIX TIME National Champion coach Nick Saban

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Basically there are 2 approved Javelin configurations on file with the FAA. Javelins produced in 1989 and earlier(Before RSL) and Javelins produced after 1989(RSL installed). By removing a RSL component you are altering the newer FAA approved system to match the older FAA approved system. He stated that because the paperwork is already on file with the FAA for a Javelin without an RSL then nothing other than a master riggers signature is needed.



FWIW, I'm running with this info for my customers. I'll attach this info to the RSL info letter from Sun Path and go about business as such. Thanks for the more detailed explanation/info.

Mike
ChutingStar.com

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Well lucky for me this inspector knows me good enough to know I'm more then able to do the job.
(inspector who used to jump and is very informed on the use and non use of an RSL) FYI the inspector thinks this is all really stupid, but that is the rule, and was telling me just put the thing on again and go get signed off and in compliance. I'm 100% sure they know I wasn't going to reinstall anything, just get my data card signed.

BTW I have now found two masters who will sign off.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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Hi Mark,

C23c came about in '84 & C23d came about in '94.

Also, a TSO Authorization holder can produce any version of their product (I am only talking about products with Minor Changes) whenever they want. This means that UPT could still produce the original version of the Wonderhog, if they wanted to.

Jerry

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Hi Jan,

Quote

Does that need yet another FAA TSO?



I was 'told' at PIA (I do not have anything in writing so am using 'told') that:

UPT/Vector added the SkyHook without going through a Minor Change.

Sunpath/Javelin added another flap (req'd for the SkyHook) via the Minor Change process.

Again, this is what I was told.

Jerry

PS) I 'understand' that the PIA committee for the TSO standards is considering some type of testing for certification if a SkyHook is used (M.A.R.D. = Main canopy Assisted Reserve Deployment in their language).

Here's a question for you Jan: what req'ments would you want in the standard?B|

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Hello Jerry!

I agree a manufacturer could produce any version of their product. But the way I read it, Sunpath's position is that because there is an approval for a non-RSL version of a C-23c Javelin, there is no need for further approval of a non-RSL version of a C-23d Javelin. Is that a tenable position?

Mark

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I would bet you that the crwdogs and camera jumpers are going to just say to hell with sunpath and disconnect their rsls in the plane before jumping.



which creates a very real safety issue. I know about this first hand as I had to have an RSL fitted to my container in order to jump with out an AAD ($$$reasons) in Australia earlier in my career.

As a camera person I was not required to have the RSL connected due to camera helmet complications.

So I had to have a RSL fitted in order to jump but I didn't have to have it connected. So i now have a lanyard with a small spinnaker shaclke free to entangle
itself in my 3 ring?

Is that not correct?

It is said that the RSL must be connected but if people have to have them re fitted in order to jump you can be sure that not all of them will have the thing connected when they jump (especially CRWdogs and Vidiots). I have heard horror stories of people simply clipping the loose shackle to the 3 ring system!!! this is a pretty stupid thing to do but people being people do stupid things!

So IMHO this is a true example of how Bureaucracy gets in the way of common sense and safety.

If they can amend the paper work to allow the fitting of a skyhook (= major alteration) then why can't a simple thing like this(= no alteration at all) be amended by the company at a paperwork level instead of passing the costly and sometimes impossible, responsibility to the consumers?

why are the other companies not forced to do the same thing? Is their paperwork more up to scratch?

I don't want to judge at this stage but it all looks as though it could have been handled a little better and I'm sure Sun Path didn't want to do this, or did they?
SKYDIVE KILIMANJARO
'Absolute Adrenalin Africa'

http://www.skydive-kilimanjaro.com

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When you disconnect the shackle you do not leave it flapping, you just clip it to your housing. I thought everyone did that? :S
No safety hazard, unless you forget to disconnect it before a jump where you should have.

ciel bleu,
Saskia

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This mandate affects my work as my partner has a Odyssey and the has never had the RSL fitted since new!

She gave away the lanyard a year ago and now the closest rigger is 4000k'm away we have bookings and cannot legally offer video? it is just the 2 of us here.

where do we stand!

we are in africa.
"When the power of love overcomes the love of power, then the world will see peace." - 'Jimi' Hendrix

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Yes I know, the Shackle that was fitted to my rig was large enough to connect the spinnaker to a 200' yacht.

I personally tucked it under my reseve risers! I was so emarressed about it at the time, I was even hassled.

that was 2800 jumps ago now though and i have learned many things and seen some very stupid things done by people that seem to be oblivious to the repercussions of such actions.

Human error should be omitted as much as possible. This mandate is making the likelihood of such errors more likely.

That is just my opinion.
SKYDIVE KILIMANJARO
'Absolute Adrenalin Africa'

http://www.skydive-kilimanjaro.com

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The rig is only "unairworthy" by FAA standards. If you're in Africa surely you only need worry about whatever the local regs say about the rig?

On that note, does anyone have any idea what's going to happen with this issue in other jurisdictions? What do the UK CAA regs say about alterations??

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He stated that because the paperwork is already on file with the FAA for a Javelin without an RSL then nothing other than a master riggers signature is needed.



Actually, that would be incorrect!

Here's why:

When a product leaves the factory or the manufacturer's control, any alterations fall under section 8 of AC 105-2C.

There you will find vivid instructions dealing with "field" alterations.

Also remember the FAA's definition of an alteration.
An alteration is considered any change to the original manufactured configuration.

In other words, a change from the way it left the manufacturer.

Another note: a manfacturer cannot give added privilages to a Master or Senior rigger.
In this case, simply not doing the required paperwork.

When the item is outside of the manufacturer's factility, it then falls back into the FAA's lap, hence Section 8 of AC 105-2C.

Do not confuse the issue with TSO this and that!

If it left the factory with an RSL, it will need complance with Section 8 , complete with paperwork, to be legal.

If it has been removed, it can be installed again by a Master rigger and will need only a notation on the Data card and his or her logbook as it is simply a "replacement".

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

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Maybe the reason is because they are going to introduce the Sky hook? This is a way to have it mandatory and to make money faster on this item?
Why not...
Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468

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That was my interpetation of AC105-2C also. It seemed pretty clear that you had to get permission from the FSDO for an alteration, but after talking to SunPath their stance was a Master rigger could remove any compentent of the RSL(as long as he properly documented it) because they had already received FAA approval for the system with and without an RSL. I think this whole deal is just going to turn out to be a huge mess and pain in the butt.
It leaves all the field riggers in a grey area when the FAA says one thing and the Manufacturer says another.

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