Notice of Proposed Rulemaking 180 day inspection cycle

[councilman24 36]

Today, May 22, 2007, in the United States the Notice of Proposed Rule Making (NPRM) to change from 120 days to 180 days the inspection cycle for emergency and reserve parachutes was published in the Federal Register by the FAA. It is Docket No. FAA-2005-21829 and can be found at http://www.regulations.gov. Search on keyword 'parachute'. I haven't found a way to link directly to the document.

Direct link from Dave below, thanks http://dmses.dot.gov/docimages/p101/470180.pdf

This DOES NOT mean the rule has changed! It means that the FAA has proposed the change and is soliciting comment. The guidelines and methods for submitting comments are outlined in the NPRM. The deadline for comments is August 20, 2007. All comments are made public.

Thanks to Allen Silver and others at PIA and USPA for their hard work and many other organizations for their support at getting this proposed change to this stage. There has been debate and differences of opinion within PIA and the skydiving community for decades on this issue. I expect it to continue.

PIA Rigging Committee Chairman

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[councilman24 36]

Pilot emergency rigs and skydiver single harness/dual parachute and dual harness/dual parachute (tandem) reserves are proposed to go to 180 days from 120 days. Also skydiver mains, which currently have to have been packed within the same 120 days are proposed to go to 180 days. But TANDEM MAINS remain unchange with NO time limit. I've pointed out this oversite before but it didn't get in the changes.

I don't believe there is any reason for tandem mains to be different. AS A PRIVATE INDIVIDUAL, I've already pointed this out unofficially to the FAA and plan to make it official shortly. PIA has not taken a position on this issue.

editied to make clear what is my personal opinion and not that of PIA

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[airtwardo 6]

I listened to the debate at PIA, some good points were made.

In your opinion Terry, does it have a realistic chance of passing?

any word on the 20 year life cycle thing?

~ If you choke a Smurf, what color does it turn? ~

[councilman24 36]

I'm not about to predict the final decision but it wouldn't be proposed if it didn't have a chance (good chance?) of becomeing final. I know many close to the issue believe the rule change will proceed. During my few discussions with the FAA they have made it clear that it isn't a done deal. Of course that MUST be the official line because all input during the comment period must be considered. And I believe it will be.

I don't remember how to get to it but you can find all of the comments along with who wrote them concerning the 2001 change to add tandem. 180 days was considered then, or at least commented on. It's interesting reading. Of course so is the PIA position on 180 days on the PIA website under documents. NOTE THAT THIS IS FROM 1999 and NOT CURRENT. I wasn't chair of the rigging committee then and wasn't a voting member then either.

Also note the justification is not that it will work anyway but that the parachute is damaged less by less handling and this justifies the change.

I was an advocate of testing years ago. But of course we don't know if parachutes packed 120 days meet TSO opening time/distance requirements let alone if 120 and 180 days are different. PD has data but I don't believe they have shared it. Last I knew they also had a waver request filed with the FAA for 360 days for their products. I never asked them though if their parachutes were 360 days would the H/C's still be 120 days anyway?

As to the 20 year service life. That is NOT a FAA rule initiative. It is solely a manufacturer's initiative for their manuals. I don't know of any changes since the PIA symposium.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[pilotdave 0]

Direct Link: http://dmses.dot.gov/docimages/p101/470180.pdf

Dave

[JerryBaumchen 1,050]

Hi Terry,

Thanks for the info.

Did you point out that the skydiver mains should have NO TIME LIMIT or did you point that the Tandem Mains should have the time limit?

I would prefer that main canopies not be regulated in any manner by the FAA; after all, they do not in any manner regulate the design, performance, etc.

Just my thoughts,

Jerry

[councilman24 36]

No, I pointed out that tandem mains should be treated consistent with other mains and have the same time limit.

As you know, mains have been regulated all along with all of the same requirements as reserves except for the record keeping. (and TSO of course) Part 65.111 that changed in 2001 to read that the next guy jumping a main could alter it was determined by the FAA, after I pointed it out to the right guy, to be in error, not what was intended and they are working on a final rule to fix it. I expect that to happen in this summer. That's the perennial debate about who can do what to a main.

All most all of the manufacturers that were setting in a PIA rigging committee meeting thought that mains were unregulated when I asked for a show of hands. These were all mainly old timers. That's pretty much what I was taught. I think it stemmed from the lack of documentation. "So, if you don't have to sign it anybody can do it." Kind of the more "relaxed" attitude toward regulations in the past. In fact as I understand a main manufacturer can't even repair a main unless they hold a repair station license OR have a master rigger do/supervise the work.

Yes, yes I know anyone can make their own main, but they can't repair it.

Unregulating mains would be a much bigger step than simply taking the 120 or 180 day requirement off them. And I think it's a step that the FAA is not willing to take. I may be wrong about that.

An arguement can be made that tandem mains should be regulated more closely since uninformed passengers are along for the ride.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[strop45 0]

What are the 'risks' associated with lengthening the repack cycle? In NZ we have 6 months, in parts of Europe its currently 12 months?

Looking through this forum there appears to a considerable number of reserve packing concerns raised by riggers looking at the work of other riggers. Might it not be better to have a longer repack cycle, but require two riggers to sign off on the work - one doing it and one just watching and making sure its 100%?

The difference between stupidity and genius is that genius has its limits." -- Albert Einstein

[klingeme 0]

Quote

I would prefer that main canopies not be regulated in any manner by the FAA; after all, they do not in any manner regulate the design, performance, etc.

Mains are regulated in the fact that only the owner, Rigger, or someone directly superviesed (very loosely interpreted) can pack a main.

Mark Klingelhoefer

[packertom 0]

just to throw a monkey wrench in the works.. with the growth of pond swooping and more people jumping wet rigs.. should there be a provision that any reserve parachute immersed in water or suspected to be wet should be inspected and/or repacked prior to being placed back into service?

just a question... so all you pond swoopers don't freak out and jump on me

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

[tombuch 0]

Quote

I listened to the debate at PIA, some good points were made.

In your opinion Terry, does it have a realistic chance of passing?

any word on the 20 year life cycle thing?

My sense is that it has a terrific chance of passing. This change has been contemplated for years, and the FAA finally made the effort to publish the proposed change. There were plenty of ways they could have gummed it up, but they decided to go with the easiest and simplest change possible. It's unlikely there will be sufficient objections to cause a rethink.

For what it's worth, I have many objections and offered them in my own comments to the docket on September 12, 2005 (see: http://dmses.dot.gov/docimages/pdf93/345005_web.pdf. None of those suggestions were incorporated in the proposed rule. I think the FAA is happy with the proposed change, and while they will certainly entertain comments, I doubt there is much room for alteration of the final rule.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

[kallend 1,635]

Quote

just to throw a monkey wrench in the works.. with the growth of pond swooping and more people jumping wet rigs.. should there be a provision that any reserve parachute immersed in water or suspected to be wet should be inspected and/or repacked prior to being placed back into service?

just a question... so all you pond swoopers don't freak out and jump on me

One can always opt for an I&R prior to the mandatory date if one has any doubts about the airworthiness of one's reserve.

...

The only sure way to survive a canopy collision is not to have one.

[floormonkey 0]

No.

It takes more then a brief immersion to have an effect on a reserve deployment.

Also, who would regulate "suspected to be wet" or even enforce a total immersion rule? What if someone sweats heavily and it looks wet?

This is a sport of personal responsibility. Let's leave it that way.

[bofh 0]

Quote

What are the 'risks' associated with lengthening the repack cycle? In NZ we have 6 months, in parts of Europe its currently 12 months?

I'm not a rigger, but this is what I recall from talking to a rigger about it:
A 12 month cycle was considered in Sweden, but one of the main arguments against it was that the reserve pack shrinks the longer it has been packed and thus the tension on the reserve loop becomes less, increasing the risk of a premature opening. Apparently the military has had some problems with that (they have a 12 month reserve repack cycle). The proposed change also involved a rigger inspection of the system every 6th month so the riggers would see the system just as often.

[kenneth21441 0]

I feel that this proposed change with have both the good and bad points of our sport.
One thing that concerns me the most is the actual control of the canopy once its packed who is to say that the owner will do the right thing in storing it. Ive seen some people keep there packed rigs in the cars trunk for months on end only to take it out to jump. Remember the cars temp can reach over 100 degrees in the summer or more.

The other area is making sure that the rigger is doing what he is suppose to do, when he or she receives the rig for repack. Are they really taking the time to inspect that canopy, suspension lines, and harness from top to bottom and inside and out. It takes me over an hour and half or more to check these areas as I dont want to miss a thing. Plus I always let the canopy air out for 24 hours. This of course came from my army training. Ive seen some who open the container, spread the canopy out and repack it all with a 2 hour period. Is this wrong or am I just being to causious?

I will be sure always.....

If the rules d change I hope that our riggers will at least let the canopy airout for a day and do that 100 percent inspection closer. As they will not see that canopy for another 175 days or so.

Id even go as far as making a care list for the customer so they will asssit me in taking care of the rig durning that 180days... in handling, storing, etc..

How many of you have seen stains on the container for soda/ pop or others .... ever wonder what that will do after 180 days... with out the proper care?


Just my two cents on this issue. as I do support the change but we must also prepair for it in doing the right thing.......

thanks,

Kenneth Potter
FAA Senior Parachute Rigger
Tactical Delivery Instructor (Jeddah, KSA)
FFL Gunsmith

[diablopilot 2]

What in your opinion does airing the canopy do for it?

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

[kenneth21441 0]

My opinion is just that as everyone else has a A or a B hole.

As I recall from reading my regs ithe FAA leaves it up to the rigger to air out the canopy. It does not state the time frame.

But as Stated before it was our SOP to air the canopy (reserve) out for at least 24 hours before we repack. Why? I dont know but as I think of it. our rigs have been exposed to alot of things during there 120 days of pack and if a small stain of somones sweat, drink etc.. was on the canopy this 24 hours helped dry it and if it caused some discoloring we would find it orif it was wet by the inspection it was dry.etc.. Ive seen some slightly damp canopy maybe from condensation or whatever. It does not hurt plus it makes a good practice in following the Regs. Of course if they are wet, wet and 24 hours is too short then they air out longer with a fan.

To this day I still practice this. And plus I never want to have a customer come to me with a rush like I need this for the morning. Ill tell them no and if they want to watch it repacked come back in 24 hours...

No one should have a problem with this.

Kenneth Potter
FAA Senior Parachute Rigger
Tactical Delivery Instructor (Jeddah, KSA)
FFL Gunsmith

[diablopilot 2]

I've just wondered what the "air" is suposed to be for on a "dry" canopy. Thanks for your views.

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

[councilman24 36]

I just packed two pilot rigs that are used in a Korean era jet. The rigs smelled so bad of jet fuel that I couldn't keep them in the house. I had to air the canopys out in the garage. It took several days for the smell to disapate.

This is one case where airing had an effect. I've had others also.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[tombuch 0]

I use the "air" component to help take the "set" out of the canopy. If you open the reserve and pack it right away the canopy almost folds itself back up along the prior folds, making it super easy to pack. If you thrash it around a bit and hang it up for a day or two, those folds break down, and the new folds are in slight different places. That makes it a bit harder to pack.

When I pack my own rig I'll open it up for inspection and then repack immediately twice a year, and let it sit and really air out for a few days once a year.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

[billvon 2,406]

>Remember the cars temp can reach over 100 degrees in the summer or more.

100F? When we design for car environments, we make sure we go to 85C (185F.) We regularly see 65C (150F) in closed truck cabs in Arizona.

That being said, I don't think temperature alone damages canopies and/or rigs. It can, however, damage cypres batteries, and thus high temps are good to avoid for that reason.

>ever wonder what that will do after 180 days... with out the proper care?

I honestly don't think there are spills/dust/grease/water issues that are fine for up to 120 days but are damaging beyond that. A rig that gets wet (and stays wet) will see mildew form within a few weeks.

[riggerrob 558]

Any word on the 20 year life cycle thing?

[riggerrob 558]

Might it not be better to have a longer repack cycle, but require two riggers to sign off on the work - one doing it and one just watching and making sure its 100%?

[PrairieDoug 0]

Here's a link to an article from the Business section of today's Washington Post on the 180 day proposal: http://www.washingtonpost.com/wp-dyn/content/article/2007/06/04/AR2007060401789.html

The column states that "virtually everyone in the industry supported the change, including manufacturers and material suppliers, pilots, skydivers, smoke jumpers and riggers, who do the actual packing."

There are a couple of glaring factual errors. USPA membership is listed at 3,500 and freefalls are reported as occurring "from 1,200 feet at 150 mph."

Doug

[SpecialKaye 0]

If you're not a rigger, then the liability is upon the rigger you are working under. I'm sure you are aware that you MUST work under direct supervision if you are not a certificated rigger. If a rig is brought to you to be packed that is wet, have the rigger you are working under make the call, not you. I'm not really sure how I would handle that one.

I know at Bridge Day we pack up wet, usually try to dry out the canopy a bit, it's not sopping wet. I don't really know I would want to worry about a reserve being wet, sopping wet, when you're skydiving, especially since you don't know how wet the reserve is.