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packertom

JAVELIN RSL... IMPORTANT, MUST READ

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I have a number of problems with this "policy".

1. (Until they recently updated it) it did not seem to consider those activities in which an RSL is an arguable liability. Camera and CRW were already mentioned, but there are others, such as skysurfing (yes, there are still some of us around) and some other freefall toys. I imagine tube jumpers might want to be able to ditch the tube and their main in the event of an entanglement before their RSL does them any favours. Being allowed to disconnect it before the jump renders the whole thing kinda pointless. Why not just remove it???

Even if I have a place to put it, it's still more crap sticking out unnecessarily.

2. There is a world of difference between removing the lanyard and removing the rings and/or velcro. Removing the lanyard requires no tools or removal of any stitching. While I see valid reasons to remove the lanyard, I see not point in removing the rings or velcro. Leave them there in case you ever change you mind or sell your rig.

3. The lanyard is *designed* to be removed. That's why it's not sewn or fastened. How is this a mod?

4. Removing the lanyard only is not "permanent". It can be reinstalled most easily during reserve repack, or with the aid of a single temp pin, at any time. Granted, this is rigger work (senior or master).

5. (And this is the big one). If removal of the RSL lanyard is illegal, then this ruling makes it illegal to cut away a main from a Javelin when an RSL is installed and connected. As written, the user "The user can “disengage” the RSL lanyard by disconnecting the snap
shackle, only in an emergency situation." This means the only way a user can remove the RSL is by unhooking the snap shackle. When you cut away, the snap shackle is the only thing still connected (usually). Sounds ridiculous? If we're interpreting the bulletin to make it illegal to remove a removable component, then the same "interpretation logic" (or lack thereof) can be applied here.

This isn't one of my beefs, but one answer to the question why there is no date to this is that the law has always been in effect (at least long enough to cover this). This bulletin is simply interpretation. This is also why there is no grace period to comply. It's a federal regulation that has been in effect, and Sun Path does not have the authority to grant a grace period to a FAR.

Ladies and gentlemen, this is seriously weak.

(>o|-<

If you don't believe me, ask me.

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Here's my interpretation of the FARs.
* FAR 65.129 d&e says a manufacturer can authorize an alteration.
*Advisory circular 105-2C Sec. 8 (which is not an FAR and therefore not law), forgets to mention that a manufacturer can authorize alterations.
If any conflict between the two exists, FAR part 65 should be followed.
Sun Path has specifically authorized removal of the RSL by a master rigger in their latest bulletin. We don't need FAA authorization.



Mark,
Ac 105-2C is legal guidance to expand the rule.
It is also used to help define the Pre-amble.
It can and will be used in a court of law.

Also,
Sun path does not recommend the removal so I do not see their wording as an approval. It just states that if you do remove it, it will need a Master rigger's signature and log notation.

All field work needs paperwork. Most people just elect not to do it or maybe they just do not know it needs to be done.

An approval from the manufacture may be subsituted for the engineering drawings and other data spelled out in chapter 136 of the inspector's handbook.

The paperwork still needs an inspector's stamp of approval.


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Here's my interpretation of Sun Paths Letter dated 2-27-2007,
Question #5 response from Sun Path says a master rigger can "approve"and"certify" a previously removed RSL with notations on "data cards/logbooks".
In the case of a simple lanyard removal,a master rigger could approve,(or not approve) the alteration without unpacking the reserve.



I do not find in the FAR's, the inspector's handbook, or any other FAA reference where a Master rigger is allowed to approve or disapprove an alteration.
Everything points to the administrator(FAA).

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

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All field work needs paperwork.



I respectfully disagree, and I offer Mirage PSB-1204 as a counter-example. Drawings for the installation of pockets and channels for an AAD are part of TSO approval. Moving the cutter is an alteration of the approved configuration, even though it's a "minor change."

Mark

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Mark,
Did you not fill out the paperwork???

I did!


I'm also not implying that you did not but, I also bet that most riggers did not even log the work as being done.

But that is a different story I guess....


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

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Rigs sent to Mirage's service center came back without any paperwork except a notation on the data card.



That makes me wonder if it is even a completely legal alteration!

BS,

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

As long as the modification is recorded in Mirage's TSO archives, it is a legal modification.
For example, while working for Rigging Innovations, I did hundreds of Cypres retrofits, RSL installations, harness resizes, Service Bulletins, etc. but rarely noted them on reserve packing data cards. Sandy's attitude was "as long as there is a sheet in the TSO certification paperwork, we are covered."
All those (modification, update, etc.) sheets ended up in Rigging Innovations' dusty archives of production records.

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Rigs sent to Mirage's service center came back without any paperwork except a notation on the data card.



That makes me wonder if it is even a completely legal alteration!

BS,
MEL



If the manufaturer did the work and documented it, I think it is safe to assume it is.
----------------------------------------------
You're not as good as you think you are. Seriously.

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So if Sunpath can make alterations to the design and get it approved under the existing TSO via a Minor Change, or no change at all, why doesn't Sunpath just file for acceptance without the lanyard? Seems like them getting the system TSO approved without the lanyard (which is not permanently secured anyway) would resolve most of these issues.

Is there any reason Sunpath is not trying to be part of the solution here? Seems like they could easily solve this for their customers instead of stirring up all the problem and washing their hands of it.

I also don't understand why a Master Rigger is required given the lanyard is not permanently secured. Removing the velcro and ring I can see, but not the lanyard. I'm sure this has to do with modifications to the container and the legal aspect instead of common sense, but why can't Sunpath just authorize this as well? If they are standing firm because they think RSLs are safe in all situations, they're going to lose even more credibility and respect IMO.

They are going to lose a lot of customers if they don't become part of the solution quick!

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As long as the modification is recorded in Mirage's TSO archives, it is a legal modification.


Rob,
Yes, IF it is done within the domain of the FAA approved facility of the manufacturer.

Not if it is done out in the field.

Again, when the product is outside of the manufacturer's facility, it is considered "in the field".

This is when we, "field " riggers,have to abide with the procedures set forth by the FAA for us to comply with.

For reference, Section 8 of AC-105-2C and also Chapter 136 of the inspectors handbook are some of them.

In the past we have done things not exactly as the FARs have stated and have grown accustomed to that mode of operation.

Now, it seems the FAA is taking note of that.

Quote


For example, while working for Rigging Innovations, I did hundreds of Cypres retrofits, RSL installations, harness resizes, Service Bulletins, etc. but rarely noted them on reserve packing data cards. Sandy's attitude was "as long as there is a sheet in the TSO certification paperwork, we are covered."
All those (modification, update, etc.) sheets ended up in Rigging Innovations' dusty archives of production records



Exactly!

If the work was done by the manufacturer"In-House"
It prefectly legal.

On the other hand, if Rigger Joe Blo did the work outside the facility, Section 8 needs to be complied with your local FSDO.

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

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I think there is a bit of misinformation about our service bulletin and who can do the work.

It is stated that any master rigger can perform the service bulletin whether "in house" or "in field"

True, we do have authorized service centers but that doesn't mean you only have two options of legally having the psb mod done. If you'll look over the PSB, any master rigger can make the modification.

Please feel free to contact me at [email protected] if you have any questions.

Thanks
Ward

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It is stated that any master rigger can perform the service bulletin whether "in house" or "in field"

True, we do have authorized service centers but that doesn't mean you only have two options of legally having the psb mod done. If you'll look over the PSB, any master rigger can make the modification.




Ward,
Two Points here:

First a SB does not have to be complied with like an AD does. A SB is not mandatory like an AD is.

Second, the point I am try to make here is this.

The manufacturer cannot delegate (legally) as to whom can do the work and by what standard.
That's the FAA's function.

Just because a manufacturer writes something does not make it legal.

For instance; Jump Shack had a "mod" for converting their freebags over to rubber bands.
In the bulletin in stated that a Senior rigger or Master rigger could do the job.

We all know that that is wrong for many reasons.


Cheers,
MEL

PS- PM sent
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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The manufacturer cannot delegate (legally) as to whom can do the work and by what standard.



Eh, I disagree somewhat.

The cannot have a rigger violated for performing such work.

They can legally prevent riggers from doing work without authorization by not disclosing the instructions on how to do the work, or by not providing proprietary materials/parts to complete said work.

Semantics for sure, but just the same.......
----------------------------------------------
You're not as good as you think you are. Seriously.

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Wow getting pretty technical. The main point is why now after all these years. This is bullshit. A senior rigger can install an rsl but not remove it? so now I have to spend 50 bucks. our master rigger will not sign off untill this gets cleared up.

This has everything to do with the skyhook. either on purpose or javelin messed up on the tso and the faa caught it when they looked at it for the addition of the skyhook.
_______________


"It seemed like a good idea at the time"

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I spoke with Sunpath and their rigs were TSO with and without an RSL. With this in mind you do not need additional paperwork to have a Master Rigger Remove the RSL. I have worked on a few of the early rigs which do not now or have not ever had an RSL installed. How ever all the new rigs come with an RSL

If your read the letter it also states that the jumper can unsnap the RSL So the jumper can get on an aircraft with it installed on the rig but not hooked up.

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>Only a Master Rigger may alter an approved item AND must have
>the appropriate FAA paperwork!

Are you thinking this would be a form-337 alteration?



I'm at the DPRE seminar as I type this and brought it up to one of the Course Directors (also a rigger). His opinion is that if a Master rigger signs it off. It's good as gold. Who know what a court of law would say? Therein lies the dilema.

Tim Tennant

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If a Master Rigger removes the RSL (and notes it on the packing card and in his logbook), and later wants to reinstall it, does he have to note the reinstallation on the packing card and in his logbook?

Once the RSL has been removed by a Master Rigger, may a Senior Rigger put it back on without further approval?

Now suppose a Senior Rigger finds a rig with the RSL installed, even though the data card says it has been removed. Should he remove it, or would that take another Master Rigger approval?

Mark

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