FAA: Altering Main Canopies

[tdog 0]

Quote

Mark,
Poynter's has errors as well, just not as many as the PRH.

MEL,

If:

1) Poynter's (both 1 and 2) believe a senior rigger should be able to do it. These books have gone thru major revisions and no one convinced the author to change, and the FAA looks to these books as reference materials for rigger knowledge.

2) PRH (FAA approved document, despite your belief it is full of errors) thinks a senior rigger should be able to do it.

3) There are no TSO Standards for manufacturing or testing of mains - anyone can do it - from a rigger to a college kid's science project - and the community knows that mains are not TSOed so they choose their purchase on reputation of the brand, and they choose the maintenance by people they trust, sometimes themselves.

4) The industry accepted practice is that anyone can work on anyone's main, and the skydiver alone, himself, determines if he is willing to jump that canopy - face it - it happens EVERY DAY. From a brand new student being instructed how to change the lengths of their brake lines to swoopers making new linesets and sliders of different materials.

5) There are no solid facts proving the current system is broken in the form of incident reports.

then

why not advocate and push the FAA, in the current revision process that DPREs and riggers are participating in, to change the laws to reflect industry standard practice???

If the FAA doesn't regulate AT ALL the manufacture of mains, how can they get involved in the repair? It is NOT a certified component and there is NO GUARANTEED or TESTED airworthiness from the factory floor, nor a master rigger's loft...

To me this is about a non-certificated component with no regulation on the design and manufacturing - and hence, a skydiver should be able to choose who they want to repair or fix their main.

I am confident from your posts I know exactly your opinion as to what the LAWS are.

I want to know why you are so firmly in support of them... So why do you believe a master rigger is the only one competent to repair a lineset that had no certification process in the first place, and the factory did not need any rigger or TSO process to build, approve or install?

And my motivation... Since you posted you believe I am crying that you are taking something away from my basic rigging certificuite.... It is not that.... It is...

Everyone I know with some passion towards rigging participates in the maintenance of their main. As a rigger, I am sometimes delivered mains. I am sometimes delivered mains people are thinking of purchasing for "inspection".

If I don't ground a main that I believe is airworthy but I believe is altered - I am accepting liability. If I know it is altered, I have no way to prove who did it, to prove it was altered "appropriately" because you yourself pointed out no records are required to be kept.

You as a master rigger face the same liability. Maybe more than I, since I am not to be trained and tested, per your previous posts, on basic line replacements, so there would be no way to prove I, as a senior rigger, should have the knowledge to identify repair techniques, but YOU DO....

It is far, far fetched that I would be in a court room, especially if I conduct myself professionally... But, it would suck to face a wrongful death civil suit because of a main that passed thru my hands for "inspection", but a family trying to find closure took out their pain on me...

That is why I advocate rules = accepted industry practice, good rules = enforced and followed....

[tdog 0]

And... Motivation number two... Since I only rig for friends and people I know...

I know I can replace a line, I was trained to do it by a master rigger, I have done it...

A friend delivers a canopy to me. I say, "your steering lines suck. You need new ones from the cascades down. You need to take it to the only master rigger in our state who is actively working right now, but he is on vacation, or send it the factory."

He says, "I will when I have time... I already have my airfare tomorrow to the boogie. Too bad you could not fix it right here and now."

He then has a malfunction and...

I would feel worse in my heart that I followed the (I believe silly) regulations than just fixed the problem...

I mean, a steering line required a fingertrap, which I train all my aff students on so they can make a closing loop, and a bartack. With some talent, a few tools, you can even make it the right length on the first try! This is not rocket science.... (Note, if it was his reserve or something TSOed I would have no problem saying, "I hope your airfare is refundable or you can find someone out there to pack your rig, because I can't.")

Face it... Skydivers take the path of least resistance. If you can do a relatively simple line replacement for a friend, they will allow you to. If you require them to go way out of their way, they are less likely to get the repair done, and add danger to the system.

[jheadley 0]

Regarding replacing steering lines, I always thought it was funny that in Dave DeWolf's senior rigger's course (Mel is one of the instructors BTW), they teach you how to replace steering lines, then they tell you that you actually aren't allowed to do it.

[masterrigger1 2]

Travis,
You obviously have a passion for rigging...I greatly admire that.

A far as the reason I am sticking to the FARs is this:

One they are the FARs and I have to teach the content properly.

I see many botched relines every year and about 99% of them are senior riggers and owners doing the work.

Line sets installed on the wrong sized canopy.

Bartacks that are not appropriate.

Stabs tacked down wrong.

Line sets manufactured incorrectly.

I know of at least three incidents to have caused great bodily harm thought to have come from "homemade" line sets or just mis-installed ones. Again by either non-riggers or Senior Riggers.

Now how do you seperate the bad from the good?

Well, if you follow the FARs you definitely stand a better outcome IMO and you are following the regs.

Sure there are people out there that can do the work that do not have a master rigger certificate, but they are like me right now.

I am a very good mechanic and there are things that I cannot do to my airplanes without an A&P Certificate legally.

I am working on my A&P just to be able to do it without the possibility of "crossing" the line so to speak.



Now if you really want to debate something, how about this.

I am guilty of not knowing this until about 1 year ago.

When a certificated parachute is packed under the supervision of an appropriately rated Rigger, that parachute must be not used.

Only a certificated rigger can do the work.


There are no provisions for supervision on a parachute packed for emergency use.

Supervision is only for the main.

Look it up in 65.111. Paragraph A is where you will find it.

Paragraph B covers the Main.....



MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

Quote

AC-105-2C spells out that replacing a line of a main canopy is a major repair......

To me there is no question..... there are also other references that I have used. One is a controlled item that only DPREs and FAA personnel have.

Cheers,
MEL

"Controlled item that only DPREs and FAA personnel have" is not a public standard, therefore not an enforceable standard.

My copy of AC 105-2C is different than yours. Mine omits the qualifier "main." The quote from section 12 is: "Examples of major repairs are replacement of a canopy panel or suspension line, or sewing a large patch on a canopy."

I assert that my reading of that sentence as: "Examples of major repairs are replacement of a[n approved, i.e. reserve] canopy panel or suspension line ... " is just as acceptable as your reading, does not conflict with any FAR, and has been the industry standard practice since 1972.

I am confident that in a court of law, my expert would prevail.

Mark

[masterrigger1 2]

Mark,
Here the final on it.

Show me where the definition of major repairs and minor repairs are seperated in the FARs with regard to a main and reserve.

There is absolutely no seperation or difference anywhere in any guidance.

A Major Repair is a major repair no matter whether it is on a main or reserve.

The FARs state that a Master Rigger can do major repairs and alterations, where as a senior cannot.

AC-105-2C states that a line replacement is a Major Repair.



I am betting my expertise truimphs yours.....

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[rushmc 18]

I am following this thread with great interest, TO LEARN and so I have questions.

In regards to the botches and mistakes you have seen with line installation and making. You use this as a point to support your position that seniors (in your opinion I might add) should not do line replacement. NOw extend to the following....

I would bet you have seen other mistakes and screw ups by master and lesser riggers. Do you take the position they should not do (what ever you seen) because they mess up?

Also, what if a rigger installs a set of manufactures lines?

I have $1000 invested in a Pfaff in my basement. Center stop center start. When I got it none of this was an issue.
Why is it now?

Again, I am learning. If I am banned from replacing lines you wnat to by and dam nice rebuilt bar tack machine?

Marc

By the way, I will not do line sets on tandems. I think more is involved here. (except for steering line repairs. I do have my limits. The first one I did was my own. I went to a DRPE to get specific training to make and install lines before I ever attempted it. I spent two days on this so I do not take it lightly and I have only installed factory sets

"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

[mark 102]

Quote

Mark,
Here the final on it.

Show me where the definition of major repairs and minor repairs are seperated in the FARs with regard to a main and reserve.

There is absolutely no seperation or difference anywhere in any guidance.

A Major Repair is a major repair no matter whether it is on a main or reserve.

The FARs state that a Master Rigger can do major repairs and alterations, where as a senior cannot.

AC-105-2C states that a line replacement is a Major Repair.

I am betting my expertise trumps yours.....

MEL

MEL,
Here's the final final:

The definition of major repair is tied to its effect on airworthiness. There are airworthiness standards for reserves, so line repair or replacement on a reserve is work for a master rigger. Because there are no airworthiness standards for mains, repairs to a main parachute cannot by definition affect their airworthiness -- you cannot go lower than zero --, ergo the repairs are not major and can be done by a senior rigger.

Cheers,
Mark

[masterrigger1 2]

Mark,
Here is the final - final of finals...

If you go by that assumption. the damnn thing will not fly!

Quote

MEL,
Here's the final final:

The definition of major repair is tied to its effect on airworthiness. There are airworthiness standards for reserves, so line repair or replacement on a reserve is work for a master rigger. Because there are no airworthiness standards for mains, repairs to a main parachute cannot by definition affect their airworthiness -- you cannot go lower than zero --, ergo the repairs are not major and can be done by a senior rigger.

That's not what the FAA thinks and I think I will follow their cue.


The new AC should have enough definitions and guidance to remove the "trapdoors" everone tries to fall though.

The FAA is changing up alot out there with LSA, Ultralights, Weight-shift and etc.

It will be intererting to see what they come up with.

MEL


PS
***
The FARs require that you follow the manufacturers recommendations, instructions, etc...
99.9% of the main canopies today are manufacturered by some one other than the person jumping it.

I bet say PD( along with the other manufacturers) has a airworthiness standard that they want to be met. I never asked though.
I do know they take canopies out of service because they are no longer airworthy.

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

Quote

The new AC should have enough definitions and guidance to remove the "trapdoors" everone tries to fall though.

You and I both need copies of the draft before the new AC goes final.

More importantly, the FAA needs industry input on this and the other issues you've brought up. Specifically, PIA (in the persons of the President, Cliff Schmucker, and Rigging Committee Chair, Terry Urban (Councilman24)) must solicit and develop a consensus view and interpretation of the FARs (and ACs, Orders, etc.) that the FAA can accept and we can live with. I hate to think our community could blow this opportunity to make things right, but we could wind up with the regulations as muddled as they are now, just in a different way.

I have a refrigerator in my loft. The IRS thinks I need it to keep batteries cool. There's a cold beer in there for you the next time you're in the area.

Cheers,
Mark

[masterrigger1 2]

Quote

I have a refrigerator in my loft. The IRS thinks I need it to keep batteries cool. There's a cold beer in there for you the next time you're in the area.

Cheers,
Mark

Same here! In fact I need one now after all of this flipping typing....

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[diablopilot 2]

Quote

To me there is no question..... there are also other references that I have used. One is a controlled item that only DPREs and FAA personel have.

Forgive me, but if true, that's fucking retarded.

A document regulating rigging, that's not available to riggers?

Nothing meant personally of course Mark.

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

[riggerrob 558]

Sorry,
But I disagree.
Very a few non-riggers possess the tools, skills or data to do major repairs (relining canopies, replacing ribs, that sort of thing).
Rewriting the rules to allow - the capable, but not licensed - one percent of the population is silly.

[tdog 0]

Quote

Sorry,
But I disagree.
Very a few non-riggers possess the tools, skills or data to do major repairs (relining canopies, replacing ribs, that sort of thing).

Tools - the FARS are clear - if you don't got 'em - you can't do it.

Data - if the data is made available to a master rigger, it is also available to the general population. There is no secret data holding ground that 200 packjobs and 3 years in the industry gives you.

Skills - ok, I agree... Replacing a torn rib is a work of art. I am not that good. I sent my canopy back to PD for that very task. I know when to say no...

Replacing a broken or worn line.... Pretty darn simple, so as long as you have access to a bartack machine. It takes hours, not years, to learn to make a quality finger trap and bartack. The tool count, other than the bartack machine, is less expensive than the line you actually will consume.

Maybe I was painting with too broad of a stroke. Maybe what I truly believe is that lines on a non-approved canopy, should be minor repairs, as I believe it is an easy task to learn and do properly.

This is supported by my personal belief that (although I am not suggesting the FARs support), a rigger cannot make something unairworthy, that never was certified to be airworthy in the first place!!! Hence, the definition of major repairs (repairs that could change the airworthiness of a component) cannot apply to non-TSO mains, as they were never TSOed or "Approved Parachutes" deemed to be "airworthy" from the factory floor... Hence, all repairs to mains are minor repairs as "airworthy" is subjective without a standard to follow.

P.S. As I told MEL in a PM... If DPREs and those who issue letters suggesting an applicant is ready for testing, are not confident their applicant knows when to say "no, I don't have that skillset, I can't do it", and they are not tested on basic bartack and fingertraps, then we have bigger problems in the rigging community...

[masterrigger1 2]

JP,
It is just definitions and a bank of questions for the Oral and Practical for the DPRE to use.

Actually, we no longer are using it offically, But I still have it as reference material..

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[AMT 0]

First let me set the tone, Im asking, and NOT arguing.

This question is specifically directed at you.....How can a part determined by the FAA to not need approval, be subject to FAR's concerning mantenence, alteration, airworthiness and qualified persons?

Compare it to an ultralight, if it meets 103.01 and 103.03 than it requires no approval, certificate, etc, per 103.7. The operator doesnt even need any certificate. How do you regulate maintenance on this then? You don't. Ultralight manufacturers have airworthiness standards, just the same as PD. Im sure both would ground unairworthy products, but that would just be a suggestion, since the FARs dont require an airworthiness standard to be maintained, part 103.7 even tells you this. I don't think I've seen anything that says a main canopy must be maintained to its original design and airworthiness. Or can I interpret 65.129 to say this, but it could probably also go the other way. And of course any FAR's concerning parachutes only apply to them when used in conjunction with a US registered aircraft, which is the only way the FAA can inforce anything about them.

I have to wonder if the original intent of the FAA was to tightly regulate main canopies, particularly when they would allow 254lb unapproved powered aircraft to fly around. But then again they were once tighter then now.

The biggest question I have is that there seems to be enough people on both sides of the debate, and im not seeing anything but interpretations, how do I know you are right, and they are wrong or the other way around? Or do I just get the standard "if you read 65.111/ac105-2 its there" that I hear from everybody? obviously it isnt, or not clear enough.

Quote

The new AC should have enough definitions and guidance to remove the "trapdoors" everone tries to fall though.

Whats to say people on your side of the argument dont fall through their own interpretive doors on their way to your conclusion?


You did however provide the best advice about dealing with this debate.

Quote

follow your senior rigger certificate with a master

[diablopilot 2]

Quote

JP,
It is just definitions and a bank of questions for the Oral and Practical for the DPRE to use.

Actually, we no longer are using it offically, But I still have it as reference material..

Cheers,
MEL

Comment retracted, foot placed back in mouth.

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

[riggerrob 558]

This is supported by my personal belief that (although I am not suggesting the FARs support), a rigger cannot make something unairworthy, that never was certified to be airworthy in the first place!!!

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

You are making a leap of logic that I cannot follow.
You are confusing practical standards with legal standards.

"Airworthy" is a practical standard that applies to aerospace device.

"Certified" is a legal standard.
IOW "certified" is just a piece of paper!
Hah!

It is possible for an aerospace device to be "certified" but not "airworthy."
For example, if you drag a "certified" reserve across a barbed wire fence, it may still be "certified" (because the paperwork is intact) but no one could look at the jagged holes and say that it is still "airworthy."

Basically, you are trying to find a loop hole in a Federal Air regulation where there is no hole.

If you truly understood the process for changing Federal Air Regulations (high paid loobyists who spend many years wining and dining senators, three readings in Congress, final reading in the Senate, Presidential line-item veto, etc.) you would never open your mouth on this subject.

I wonder if you are only posting because you enjoy an argument?????

I repeat my belief that only one percent of the people - who do not hold riggers' licenses - are capable of doing major repairs to parachutes. It is silly to rewrite a Federal Air Regulation to accommodate one percent of the population.

[racine 0]

Subpart F—Parachute Riggers

§ 65.111 Certificate required.

(a) No person may pack, maintain, or alter any personnel-carrying parachute intended for emergency use in connection with civil aircraft of the United States (including the reserve parachute of a dual parachute system to be used for intentional parachute jumping) unless that person holds an appropriate current certificate and type rating issued under this subpart and complies with §§65.127 through 65.133.

(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.


Everybody read number 3 closely, then if you are questioning your legal ability to alter mains, add one jump ticket to your fee.

Packy

[councilman24 36]

You need to read the thread.

The whole point is that 65.111b is an ERROR by the FAA and they NEVER intended to allow non master riggers to alter mains. They are fixing it as we speak.

Don't come late to the movie and asked what happened.

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

[mark 102]

Quote

Subpart F—Parachute Riggers

§ 65.111 Certificate required.

(a) No person may pack, maintain, or alter any personnel-carrying parachute intended for emergency use in connection with civil aircraft of the United States (including the reserve parachute of a dual parachute system to be used for intentional parachute jumping) unless that person holds an appropriate current certificate and type rating issued under this subpart and complies with §§65.127 through 65.133.

(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.


Everybody read number 3 closely, then if you are questioning your legal ability to alter mains, add one jump ticket to your fee.

Packy

Enjoy it while you can. When this regulation was changed in 2001, this section and others were rewritten to accommodate tandems. The previous version did not permit the next jumper to alter a main, so the current version does not conform to the NPRM or comments or response to comments. I expect to soon see a correction that will:
-- allow the next jumper to pack his own main
-- require a rigger (or rigger supervision) to pack otherwise
-- require a rigger certificate to do minor repairs to a main
-- require a master rigger certificate to do major repairs and alterations

Mark

[Hooknswoop 19]

All the rambling aside, how would anyone know who altered a main canopy? There is documentation required and you are innocent until proven guilty. Changing how a canopy is packed is an alteration. Mains have been altered by anyone and everyone since they were called mains. Who cares? Has a Senior rigger ever been procequeted for altering amain canopy? MEL called the FAA on me at least once and the FAA Inspector and Master Rigger told me that since it was a main, I could do anything I wanted and that is the industry norm.

Let's just say, for the sake of argument, that altering a main canopy is manufacturer and Master Rigger territory only. Now what? What does that really mean. If you roll the nose of your canopy to see what it does to the opening, you are in violation. If you replace a line, you are in violation. So what? What will really happen?

If I work on my BASE canopy or container, am I in violation? It isn't certified any more than a main canopy is.

You can argue till the cows come home, but in the end, who cares? LOL! If the FAA wants my rigger's ticket, they can have it.

Derek

[mark 102]

Quote

All the rambling aside, how would anyone know who altered a main canopy? There is documentation required and you are innocent until proven guilty. Changing how a canopy is packed is an alteration. Mains have been altered by anyone and everyone since they were called mains. Who cares? Has a Senior rigger ever been procequeted for altering amain canopy? MEL called the FAA on me at least once and the FAA Inspector and Master Rigger told me that since it was a main, I could do anything I wanted and that is the industry norm.

Let's just say, for the sake of argument, that altering a main canopy is manufacturer and Master Rigger territory only. Now what? What does that really mean. If you roll the nose of your canopy to see what it does to the opening, you are in violation. If you replace a line, you are in violation. So what? What will really happen?

If I work on my BASE canopy or container, am I in violation? It isn't certified any more than a main canopy is.

You can argue till the cows come home, but in the end, who cares? LOL! If the FAA wants my rigger's ticket, they can have it.

Derek

I'm not sure if you are responding to me, or if my name appears in the RE: line just because it was the last post before yours.

My personal position is the same as yours: anyone should be allowed to alter his own main parachute. Actually, my position might be more extreme than yours: I believe anyone should be allowed to alter someone else's main parachute as long as (a) that other person is able to give informed consent, and (b) the person doing the altering doesn't hold himself out to the skydiving public as willing to do those alterations for all comers, whether for profit or no.

My position is not supported by the FARs, and I try to distinguish between what is and what I think ought to be.

Cheers,
Mark

[masterrigger1 2]

***
MEL called the FAA on me at least once and the FAA Inspector and Master Rigger told me that since it was a main, I could do anything I wanted and that is the industry norm.

Quote

You left out that that was with your consent.
( I still have the PM's around here somewhere)

For the people that do not know the history here:

Hook and I had about two year discussion, here on DZ.com, regarding 65.111 and who could re-line mains.

We thought the fastest way to get an interpretation was to file a complaint. Then someone had to move on it.

That inspector basically never looked up the FARs and basically shot from the hip on his reponse.

I found that out after he gave you a response.


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

• Quote

[riggerrob 558]

If I work on my BASE canopy or container, am I in violation? It isn't certified any more than a main canopy is.

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

Since BASE jumping is unlikely to ever interfere with an airlines, the FAA does not CARE!
BASE is completely outside the Federal Air Regulations .