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tdog

FAA: Altering Main Canopies

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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 .



Perfect. Then any non-certified canopy I alter/repair/etc isn't being used for skydiing, it is being used for BASE jumping, as far as I know. If someone puts a BASE canopy into a skydiving rig and jumps it, that is out of my control. Happens all the time. Strangely, I have never heard of the FAA going after anyone for jumping a BASE canopy in a skydiving rig, which may have been altered by someone other than a Master Rigger or the manufacturer. It is even recommended to jump a BASE canopy out of an airplane in a skydiving rig before actually BASE jumping with it.

I keep warning people against using small, ZP, elliptical canopies for BASE, but they just don't listen:ph34r::ph34r::ph34r::ph34r::ph34r::ph34r::ph34r::ph34r::ph34r::ph34r::ph34r:

Derek

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Call him up again and see if you get the same reponse.



Can't call him up, he retired. Too bad, he was a nice guy. We laughed and laughed on the phone. I haven't spoke with the new guy and don't intend to. I'll just keep altering/repairing all those BASE canopies.

Derek

Derek

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I'll just keep altering/repairing all those BASE canopies

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That's fine as long as you attach them to a BASE rig.

I do not think PD or any other manufacturer would agree with your theory.

If they produced a skydiving canopy, that you converted to a base rig, and then re-attached it to a skydiving rig for use, that you would ever have their approval that it is a BASE canopy now.

It also would then still be control under the rule of following the manufacturer's recommendations and instructions!

...unless you were a master rigger! (who needs no specific approval on Mains) ;)

The problem with that also is going to come down to probably main certification(or at least some standard) and legislation regarding BASE jumping and gear.

If people push enough buttons, that is exactly what is going to happen.

Look what has happened to Ultralights.

I now am having to be certificated with a Weight Shift license effective at the end of the month.
And now, I have to have a "N" number also.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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I'm lead to believe people grossly misunderstood my last post in this thread. To clarify, the original poster was wondering about who can legally alter a parachute.

65.111 (b) (3) states "No person may... 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... Is the person making the next parachute jump with that parachute."

Therefore, anybody can modify the main parachute as long as they make the first jump using that parachute after the modifications are made, hence the addition of 1 jump ticket to the fee for alterations. Until they are passed and published, what regulations are in the works have no effect whatsoever on who can alter mains.

Also, since BASE jumps aren't made from US civil aircraft (unless you're jumping off a helicopter parked on a cliff, or some other ridiculous scenario) this section doesn't cover BASE in any way.
Think, then type.

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Sir,
You definitely need to go back and read this thread!

You came to the dance late and wearing boots...

The BASE comment was dealing with BASE. Ths is no regulations on it as we speak, but if people keep putting it in a bad spotlight...well everyone else gets it!

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

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Hi mark,

I try my best to stay out of interest arguments.

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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



I absolutely agree with this position.

I have been a licensed rigger for over 42 yrs and I have always advocated that ANYONE should be allowed to work/maintain/alter any piece of equipment that is not manufactured under a TSO-authorization.

There are no standards for the manufacture so how can one impose a standard on the work/maintenance/alteration of the device.

Just my old opinion,

JerryBaumchen

PS) I worked for the federal gov't for 30 yrs in Contract Management. Our legal dep't always told us that only the feds get to interpret the federal regs/standards/documents. The courts of this nation have reinforced that for over 200 yrs.

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If people push enough buttons, that is exactly what is going to happen.



Then stop pushing buttons. Just leave it alone.

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That's fine as long as you attach them to a BASE rig.



If someone brings me a BASE canopy and I replace a line, it is not my responsibility to hook it up to a BASE container. That is their responsibility. What they do with it after I'm done with it isn't my problem. Again, my point is that this is ridiculous Who cares?

Derek.

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I have been a licensed rigger for over 42 yrs and I have always advocated that ANYONE should be allowed to work/maintain/alter any piece of equipment that is not manufactured under a TSO-authorization.
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Jerry,
Thanks for the reply.

It seems harder for the older people to accept the FAR's content.
( I am having problems with the part of 65.111 that does not allow me to supervise a repack for use).
Here again, this is something that we have always done in the past. For years and years.

You can probably remember the days of jumping with completely homemade rigs. In fact, I think you even built and jumped them before you got your TSO.

The fact remains that what we have always done in the past does not nessecarily reflect what the FAR's state or really mean .

It just means no one even cared or plain never got caught.

As far as a standard, it is a return to service standard as always as I see it.

What that standard is, only the manufacturer will know and can give you. I can't.



Come see me again sometime,

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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I have been a licensed rigger for over 42 yrs and I have always advocated that ANYONE should be allowed to work/maintain/alter any piece of equipment that is not manufactured under a TSO-authorization.

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Jerry,
Thanks for the reply.

It seems harder for the older people to accept your interpitation of the FAR's content.
( I am having problems with the part of 65.111 that does not allow me to supervise a repack for use).
Here again, this is something that we have always done in the past. For years and years.

You can probably remember the days of jumping with completely homemade rigs. In fact, I think you even built and jumped them before you got your TSO.

The fact remains that what we have always done in the past does not nessecarily reflect what the FAR's state or really mean .

It just means no one even cared or plain never got caught.

As far as a standard, it is a return to service standard as always as I see it.again, your interpitation

What that standard is, only the manufacturer will know and can give you. I can't.



Come see me again sometime,

MEL


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

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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.



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.....How can a part determined by the FAA to not need approval, be subject to FAR's concerning mantenence, alteration, airworthiness and qualified persons?




So far I havent seen you answer this, or really directly any question, but rather leave open responses that indicate personal opinion, or quote FAR's, yet not explain your interpretation.

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I bet say PD( along with the other manufacturers) has a airworthiness standard that they want to be met. I never asked though.



you bet?

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It seems harder for the older people to accept the FAR's content.



Ok so their take is not valid to this discussion but yours is?

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



what do they think? depends on the FSDO, sad yet true.

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I do not think PD or any other manufacturer would agree with your theory.



you dont think?

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



He is an FAA representitive, I've never seen one shoot from the hip on a response, thats not their job. But what do they know.

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Call him up again and see if you get the same reponse.



why, did you set him straight?


This thread seems stagnant, with nothing being contributed to bring about an answer.


If you are getting your A&P I hope your going to a 147 school, because I can think of enough interpretations to disqualify you until the end of time otherwise, but people do it all the time, I and most everbody else doesnt have a problem with it, But that is another discussion just like this.

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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.



... But I think he was referring to when you said only Master riggers (NOT seniors) would have the tools, facilities, etc., blah blah.

Also I would suggest that many hard-core experimenting swoopers have more skills, canopy knowledge and data than most riggers when it comes to tweaking their canopies ... and many are very friendly with their local riggers for the 'tools' part. Not saying right/wrong/legal/illegal.

Our 'senior rigger' loft has 7 industrial machines that can do about anything .... and I'll admit, we've done about everything with them. We've had up to 3 master riggers on site who would sign off anything we did. (Legal or not?) Happily my partner just got his master rating, and I'm working on mine so soon this won't be an issue.

I always watch these discussions with great interest; it seems that the rules will always be debated and I'd really like to know when/if we'll get straight answers. I'm not holding my breath:P

Poynters may have mistakes, but it was the man himself who saved a rigger's ticket and set precedence by rerferencing a page in his book and testifying that it was accepted practice for a senior rigger to install an AAD into an AAD-ready rig. --- that this was NOT an alteration. And in that case the feds said basically "OK. Good to know."

So it seems to me that now we have a precedent. Is it an alteration to install an AAD into an AAD-ready rig? Well, look at case ABC vs whomever - the Feds have ruled 'no' in the past. Puts me on pretty solid ground as a senior rigger.

Instead of these debates, I'd love to know more about precedence/findings the feds have ruled on. I bet they're few and far between, however.

Mel, Love ya and sympathize with all the scary line set installs you've seen from seniors .... but don't get me started on the canopies we've gotten back from master riggers with the wrong line set or wrong trim installed ..... and even with bar tacks completely missing :o.

tdog, you're making many good points. Thanks for the thread.

Peace,
Dawn

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Our 'senior rigger' loft has 7 industrial machines that can do about anything .... and I'll admit, we've done about everything with them. We've had up to 3 master riggers on site who would sign off anything we did. (Legal or not?)

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

As long as a Master Rigger is willing to sign for the repair, it is legal.

Senior Riggers doing major repairs - under the supervision of a Master Rigger - is part of the learning process on the way to earning a Master Riger license.

Then we get into a rousing debate about the limits of a Master Rigger's certificate. Generally, manufacturers publish limits on what types of repairs can be done to their equipment outside the factory.

For example, if Performance Designs says that any canopy (above lines) repair requires replacing a bar-tack, then the repair must be done at the factory. This is because comparatively few lofts own 42-stitch, center-stop bar-tack machines.

And I should not have to remind you about the clause in the FARs that loops back to "maintain in accordance with the manufacturer's instructions," which is just a polite way of saying that Performance Designs knows 1,000 more about canopy construction than any FAA bureaucrat can ever HOPE to understand.

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Is it an alteration to install an AAD into an AAD-ready rig?

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

No.
That is merely "assembling in accordance with manufacturer's instructions."

To clarify: the first time AAD "A" is retrofitted in a new type of container, the "alteration" must be done in cooperation between the AAD manufacturer and the container manufacturer.
Once the AAD manufacturer - or the container manufacturer - publish the retrofit/alteration procedure, then any Master Rigger (who has passed Air Tec's home-study course) can sew in the appropriate AAD pockets.
After that, any Senior rigger can slip that model of AAD into the pockets in that rig (assemble in accordance with manufacturers' instructions.

However, the retrofit/alteration process is limited to Master Riggers who are approved by Air Tec and is also limited to containers for which AAD retrofit/alteration instructions have been published.
For example: I cannot install a modern, electronic AAD in my old two-pin Mirage, because nobody has published retrofit/alteration instructions.

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For example, if Performance Designs says that any canopy (above lines) repair requires replacing a bar-tack, then the repair must be done at the factory. This is because comparatively few lofts own 42-stitch, center-stop bar-tack machines.




Is that an IF - or DO THEY... I would hate for people to start broadcasting that around because you put a hypothetical and someone interpreted at true.

And.... It true, do you have the reference material available for that, I would like to read.

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For example, if Performance Designs says that any canopy (above lines) repair requires replacing a bar-tack, then the repair must be done at the factory. This is because comparatively few lofts own 42-stitch, center-stop bar-tack machines.




Is that an IF - or DO THEY... I would hate for people to start broadcasting that around because you put a hypothetical and someone interpreted at true.

And.... It true, do you have the reference material available for that, I would like to read.



From the PD Reserve Owner's Manual:

"Any line, tape or webbing damage is a major repair. Lines may be replaced by a master rigger. However, it is recommended that these repairs be done at the factory.

"Master Riggers map perform repairs that do not involve taking apart any partacks on the canopy. Special bartack patters are used that are not normally found in the field..."

And the PD 42-stitch center stop-start pattern is slightly different than the standard Pfaff/Singer/Brother/Juki 42-stitch center stop-start.

Their main canopy manual does not have the same language.

Yes, I know this thread is about main canopies, not reserves. Hence Rob's hypothetical.

Mark

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Hi tdog,

This post is not addressed at you; yours is just the last post that I see here at this moment.

I wish we could keep this discussion on point and quit mixing in regs/ideas/experience with certificated canopies.

The thread line is: FAA: Altering Main Canopies

Personally, I wish that the PIA would petition the FAA to quit trying to impose ANYTHING regarding non-certificated parts. On one hand the FAA 'seems' to be saying 'We will regulate main canopies.' ( :S) but they say nothing about the main bag, the main risers, etc.

Does anyone else see the absurdity in this?

JerryBaumchen

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Hi tdog,

This post is not addressed at you; yours is just the last post that I see here at this moment.

I wish we could keep this discussion on point and quit mixing in regs/ideas/experience with certificated canopies.

The thread line is: FAA: Altering Main Canopies

Personally, I wish that the PIA would petition the FAA to quit trying to impose ANYTHING regarding non-certificated parts. On one hand the FAA 'seems' to be saying 'We will regulate main canopies.' ( :S) but they say nothing about the main bag, the main risers, etc.

Does anyone else see the absurdity in this?

JerryBaumchen



And since no documentation is required how would it be enforced?
"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

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I have in the past sewn on tail pockets to different skydiving canopies, some down and dirty right threw the tail of the canopy with no backing and base jumped those and then jumped them from the aircraft also after using them of BASE, where the canopies are now? Who knows, I sold them over the years and I'm sure at some point in time they were skydived again not by me, altered by me not jumped by me no more.

How about this, I have a Raven main/reserve I mentioned in another post, using it as a reserve now after first 300+ jumps skydiving it and had a save on it as a reserve after that. My point is I altered/patched it twice as my main and I'm not a licensed rigger. Now it's a reserve, patched, no history other than I know I patched it when it was a main and no other rigger would know that, they would just inspect it and start a new card.

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I have a Raven main/reserve I mentioned in another post, using it as a reserve now after first 300+ jumps skydiving it and had a save on it as a reserve after that. My point is I altered/patched it twice as my main and I'm not a licensed rigger. Now it's a reserve, patched, no history other than I know I patched it when it was a main and no other rigger would know that, they would just inspect it and start a new card.



I'd like to use your example to make this point: a senior rigger with the plastic barely cooled on his card (updated idiom from "ink still wet on his certificate") is charged with the responsibility every pack cycle of inspecting reserve canopies with someone else's major repairs, and approving for them return to service. Now, if he can inspect someone else's work and approve it, why shouldn't he be allowed to inspect his own?

Mark

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I have a Raven main/reserve I mentioned in another post, using it as a reserve now after first 300+ jumps skydiving it and had a save on it as a reserve after that. My point is I altered/patched it twice as my main and I'm not a licensed rigger. Now it's a reserve, patched, no history other than I know I patched it when it was a main and no other rigger would know that, they would just inspect it and start a new card.



I'd like to use your example to make this point: a senior rigger with the plastic barely cooled on his card (updated idiom from "ink still wet on his certificate") is charged with the responsibility every pack cycle of inspecting reserve canopies with someone else's major repairs, and approving for them return to service. Now, if he can inspect someone else's work and approve it, why shouldn't he be allowed to inspect his own?

Mark



What a great question!

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