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FAA: Altering Main Canopies 65.111 revision - removing "Altering"

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(This is a tangent off of a thread I started this morning. I apparently am a troublemaker today. Sorry...

While the last thread was a devils advocate - ask questions thread - to get people thinking... I think this one is MUCH MORE SERIOUS as a MAJOR rule is being changed).

Mark L.,

I have thought long and hard (ok, an hour) about something you sent me privately. You did not ask me to keep it to myself, I would have if you asked...

I am posting it because I think the community has the right to know and right to comment to the FAA before a major revision is made. I have talked with friends who are and are not riggers, and they are concerned too.

You said you believe that part 61.111 was re-written and is about ready to be published with the word "alter" being removed and this change is a "done deal". You did not indicate if you had anything to do with this change, so I am not accusing you of anything other than sharing the news.

If I understand correctly, this will mean that, I, as a skydiver, cannot make any changes to my main... This has nothing to do with hiring a rigger to do it... I am talking about myself - going to a well equipped loft, or my basement sewing machine, and making a major repair or major alteration, like a new lineset when my old one fails, or repairing a load bearing seam, for my own personal use, on my NON-TSO, non "approved" main.

I think a lot of people who make a practice out of maintaining their own gear and tweaking it for swooping will be very upset when they have to accept additional liability, or break the law, for modifying their own main... Almost every pro or near-pro swooper I know has done something to their canopy that was not approved by the manufacture. I have made my own linesets to factory specs, and made mods for the sake of learning and personal preference. My canopy will no longer be "acceptable" to fly because it is not in factory spec, nor did ANY rigger approve them... And, this removal of the word "alter" does not grandfather in old canopies or allow me to document when, who, or how my main was altered. Specifically, the main canopy has no packing data card assigned to the canopy to track who and when it was altered, which will further complicate enforcement of this rule, most specifically, allocating liability in the case of an accident where no documentation proves who did nor did not alter the equipment. Are riggers now required to take mains out of service if they have no documentation that the alteration was approprately performed? Do they get sued for not grounding the canopy when the next of kin finds out their son modified their canopy and it was inspected and passed? This is a bag of worms...

Here is the section I believe you indicated was revised and will be published in a few weeks:

Quote



(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 Sec. 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
Sec. 105.45(b)(1) of this chapter.




Community,

If this is true, and I have no proof other than a few e-mails that I will not share since I was not the original recipient, and the PM I received today, so I believe personally it is... I personally am of the opinion that this is a BAD THING. If you agree, and I AM NOT ASKING YOU TO, or you disagree, and I AM NOT ASKING YOU TO, you probably should speak your mind.

Signed, a skydiver (not wearing any informal or formal rigging hat).

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I agree that there is no need for the change, and while I have come up with many negative scenarios (like approved design paperwork for mains, and the STC or 337 equivalent for altering them) the reality is, who ya gonna violate? Skydivers (riggers not included) don't require any FAA certifications.
----------------------------------------------
You're not as good as you think you are. Seriously.

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f I understand correctly, this will mean that, I, as a skydiver, cannot make any changes to my main...


I don't think it means that at all. The old rule did not permit you to alter your main, it prohibited me from altering it. By removing the word "altering" it removes the prohibition. I will now be able to legally alter your main. If there is another reg that prohibits it, then the exception in this part is meaningless anyway.

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I'm a little confused. how is this a bad thing? The old rule is the more limiting. it's the old rule that forbid you unless... The new rule doesn't even mention it. You don't have to be granted this power.



LOL, yep, by removing ',or alter' the rule is less limiting. Not that it really changes anything at all. Since there is no documantation required for altering/repairing, or packing a main canopy, anyone can do anything and the FAA will never know know who did what to a main. I will continue business as usual, go ahead and report me to the FAA MEL, again:ph34r:.

Derek

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The change should be more complicated that your redline. The idea is that when 65.111 was changed to add tandem the FAA MISTAKENLY wrote this language that allows the next jumper to alter a main parachute. The FAA to me, independant of any communication that MEL has had, indicated that this was UNINTENDED and WRONG. The FAA intended to write the language so that it was the way it has ALWAYS been. That the only differences between MAIN canopies and RESERVE canopies has been a rigger doesn't have to keep paper work on MAINs and the next person that is going to jump it can pack a MAIN. That is the only difference in who can do what work. It has always taken a MASTER RIGGER to do a main major repair and alteration and any rigger to pack (if not the next jumper) and do minor repairs. Not withstanding that a individual at one point could buy a main kit and sew it themselves.

The change was unintended, according to an FAA review of all the change documentation and the analysis of the language by the lawyers. The FAA told me early last year that this would be 'fixed' - the discripency between published language and rule change intent, as a direct correction without public comment.

Many, many riggers, including many manufacuters that you would recognize, mistakenly believed that anybody could do anything to a main. That mains they were unregulated. I was taught that as a new rigger in the early 80's also. But that has NEVER BEEN THE CASE. Mains have the 120 day inspection and repack requirement, as I stated above the limitations on repairs and alterations and all the other regulation that reserves with the exceptions above.


Quote

I am posting it because I think the community has the right to know and right to comment to the FAA before a major revision is made. I have talked with friends who are and are not riggers, and they are concerned too.



Again, this is NOT a REVISION. It's a correction to unintended language and an unintended change that was NOT noticed during the change process.

IF you want the regs REVISED they would need to be revised AFTER the correction.

I hope this made since.

Summary,

The FAA is NOT revising a regulation, it is correcting an unintended revision caused by language published that did not reflect the intent of the FAA NPRM in 2001.

Mains have ALWAYS been regulated like reserves, except the next jumper can pack it and riggers don't have to keep records. Those are the only two exceptions after it leaves the factory. Obviously the need for a TSO is different but that's outside this discussion.

Most older riggers, maybe newer riggers, and many jumpers have been told mains were unregulated. That has NEVER been true.
I'm old for my age.
Terry Urban
D-8631
FAA DPRE

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Again, MEL has described the change as removing or alter, but the change should be more detailed than that. The FAA's intent is to revert to the previous regs as stated in my post above.

DON'T GET HUNG UP ON "REMOVE ALTER". That is not what the FAA intends to do, according to my communication with them last year. They intend to rewrite to the pre 2001 meaning.
I'm old for my age.
Terry Urban
D-8631
FAA DPRE

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The idea is that when 65.111 was changed to add tandem the FAA MISTAKENLY wrote this language that allows the next jumper to alter a main parachute.



In the "other thread" someone posted a quote supposedly attributed to a well respected rigger:

Quote


... Anyone can build a main parachute. However, if something breaks on it they either have to be a rigger to fix it, hire a rigger to fix it or just build themselves a whole new parachute.



I have read a lot of FARs this morning... I still cannot find anything that says how or who can manufacture or design a main.

§ 105.43 covers the fact that intentional jumps must have two parachutes - a main and an approved reserve. It says how the main and reserve have to be packed.

For the definitions of a main and reserve § 105.3 defines the reserve as:
Quote

Approved parachute means a parachute manufactured under a type certificate or a Technical Standard Order (C–23 series), or a personnel-carrying U.S. military parachute (other than a high altitude, high speed, or ejection type) identified by a Navy Air Facility, an Army Air Field, and Air Force-Navy drawing number, an Army Air Field order number, or any other military designation or specification number.



and the main:
Quote


Main parachute means a parachute worn as the primary parachute used or intended to be used in conjunction with a reserve parachute.



§ 65.111 says who can pack, maintain and alter the reserve {65.111(a)} and main {65.111(b)}.

So, isn't it ironic that the main has NO manufacturing requirements as part of the definition, but it seems the interpretation and push to revise (fix) the wording in the FARs is towards regulation of alterations and repairs?


I laughed my butt off in the car coming back from lunch today. I envisioned this conversation:



[FAA INSPECTOR] I understand you altered a main canopy for your friend. You happen to be a rigger and you also were not the next person to jump it. You are in violation.

[ME] Sir, you have your facts wrong. I manufactured a new canopy for my friend with various spare parts that he gave me. I did this not as a rigger, but as an everyday guy who makes things. You see, you don't have to be a rigger to make main parachutes!

[FAA INSPECTOR] What spare parts?

[ME] A complete main parachute, I just discarded the parts not airworthy to be recycled into a new canopy, and manufactured a new one with parts.

[FAA INSPECTOR] That sounds like an alteration.

[ME] Sir, the definition of manufacture is, "put together out of artificial or natural components or parts". I had parts and raw materials that were not airworthy alone, useless really, I put them together and manufactured a canopy worthy of flying.


I guess this is just a sarcastic way of saying, the system is flawed if the canopy is not manufactured to a regulation or spec, and people can't alter or make major repairs after it is made. And PLEASE, PLEASE, PLEASE DPREs and other riggers - don't push the FAA to TSO mains.:P

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I am posting it because I think the community has the right to know and right to comment to the FAA before a major revision is made. I have talked with friends who are and are not riggers, and they are concerned too.



Travis,
First, just like Terry stated, It is not a major revision.

The FAR's have always intended and stated that a master rigger is the only one to do major repairs, alterations, and etc...

A major change would be allowing any one other than a master rigger to do so.


§ 65.125 Certificates: Privileges.
top
(a) A certificated senior parachute rigger may—

(1) Pack or maintain (except for major repair) any type of parachute for which he is rated; and

(2) Supervise other persons in packing any type of parachute for which that person is rated in accordance with §105.43(a) or §105.45(b)(1) of this chapter.

(b) A certificated master parachute rigger may—

(1) Pack, maintain, or alter any type of parachute for which he is rated; and

(2) Supervise other persons in packing, maintaining, or altering any type of parachute for which the certificated parachute rigger is rated in accordance with §105.43(a) or §105.45(b)(1) of this chapter.

(c) A certificated parachute rigger need not comply with §§65.127 through 65.133 (relating to facilities, equipment, performance standards, records, recent experience, and seal) in packing, maintaining, or altering (if authorized) the main parachute of a dual parachute pack to be used for intentional jumping.

[Doc. No. 1179, 27 FR 7973, Aug. 10, 1962, as amended by Amdt. 65–20, 37 FR 13252, July 6, 1972; Amdt. 65–42, 66 FR 23553, May 9, 2001]


The (If Authorized) means aurthorized by the Administrator(FAA) as a Master Rigger.

It has not changed in many,many years.


As far as complying with the regs; most people do not. This leads people to believe that the rules are different than they really are.

Sad, but true!

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

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As far as complying with the regs; most people do not. This leads people to believe that the rules are different than they really are.



Ok, so we both agree that most people do NOT comply with this regulation. From my swooper friend who has an aftermarket removable slider, to my crew dog friend who has a different type of lineset, to my own (former) canopy that I built and installed a lines on - many skydivers and senior riggers "major repairs" or "alterations" to main parachutes.

Looking at the fatality and injury statistics, I see no concrete evidence to prove that the altering and major repairs of mains by users and senior riggers has caused any statistical risk to the skydiving population or the general public.

Further, without people like Brian Germain going out and playing with airlocks and cutting and building his own canopies, or swoopers changing their lineset trims to increase performance, the advancement of parachute technology would be hindered.

And, the FAA has no published requirement for the way in which a main is manufactured, a guy could buy a kit like they used to sell and make one, or I could build one at home. The FAA definition of a reserve (approved parachute) is one that meets the TSO standards, which specifies testing and manufacturing requirements, whereas a main is simply the primary parachute in a dual parachute single harness system.

So, why would the REPAIR and ALTERATION of a main be MORE strict than the manufacture of the same component? Why can I legally build a main, but never repair it or alter it? To me, this is a fundamental problem that everyone who has been around this sport longer than I agrees - has been an age old problem not talked about in hopes it will go away.

Hence, regardless of if the currently proposed modification to the FARs is a "Revision", "Fix", or "Change", - I think we should be advocating to the FAA that they adopt as rules what has proven to work in the field, so skydivers, DZOs, riggers, and manufactures don't get the added liability of accepting as "normal practice" something that is against the rules.

As to the applicability of a senior rigger having the skill to complete a "major repair" on a main canopy, lineset replacement and line attachments are load bearing, and are normally considered a "major repair".

I wonder why the practical test standards, published by the FAA, and administered by the DPREs for SENIOR rigger have the following tasks, as the argument I am hearing implies no senior rigger (or canopy owner) can ever do these tasks:

-->The examiner shall select at least one TASK from each AREA OF OPERATION, except AREA OF OPERATION VII. A senior applicant is not tested in AREA OF OPERATION VII Parachute Alteration.

Area of Operation 6 - Parachute Repair.
Task B - replacement of a lower steering line.
Task D - line attachment loop replacement.
Task G - cascade line replacement.
Task J - replacement of a continuous suspension line.
Task K - Suspension line replacement in a ram air canopy.

Lastly, thank you for the discussions... I have learned a lot today by having to dig thru the FARs to best understand them.

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I wonder why the practical test standards, published by the FAA, and administered by the DPREs for SENIOR rigger have the following tasks, as the argument I am hearing implies no senior rigger (or canopy owner) can ever do these tasks:

-->The examiner shall select at least one TASK from each AREA OF OPERATION, except AREA OF OPERATION VII. A senior applicant is not tested in AREA OF OPERATION VII Parachute Alteration.

Area of Operation 6 - Parachute Repair.
Task B - replacement of a lower steering line.
Task D - line attachment loop replacement.
Task G - cascade line replacement.
Task J - replacement of a continuous suspension line.
Task K - Suspension line replacement in a ram air canopy.




This is also up for review on the wording.

I notice that you left out the ones that we actually use for a Senior's test.

Any DPRE that is worth his or her salt (and knows the FAR's) would not be using the Master items for a Seniors Test.

Remember that it is a joint Senior and Master's test until operation VII. It is up to the DPRE to select the proper ones for the appropriate test!

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

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And, the FAA has no published requirement for the way in which a main is manufactured, a guy could buy a kit like they used to sell and make one, or I could build one at home. The FAA definition of a reserve (approved parachute) is one that meets the TSO standards, which specifies testing and manufacturing requirements, whereas a main is simply the primary parachute in a dual parachute single harness system.

So, why would the REPAIR and ALTERATION of a main be MORE strict than the manufacture of the same component? Why can I legally build a main, but never repair it or alter it? To me, this is a fundamental problem that everyone who has been around this sport longer than I agrees - has been an age old problem not talked about in hopes it will go away.



You are right: the FAA has no definition of "manufacturer," and no minimum standards for "main parachute."

You are also right: the FAA has no minimum amount of work you must do before you can claim to be the manufacturer. For amateur-built aircraft, the owner-builder must do 51% of the work, but there's no similar standard for amateur-built, or even commercially built parachutes.

MEL is right: it takes a Master Rigger to make major repairs and alterations. That's not the whole story, though. AC 105-2C section 12: "Major repairs to parachutes may be made by a master parachute rigger, an appropriately rated parachute loft, or a manufacturer" [my emphasis]. "Manufacturer" -- that's you!

As a manufacturer, are you authorized to do your own alterations? If you are authorized to do so by the FAA, then for sure. Further, most FSDOs will defer to your expertise as a manufacturer to determine the level of certification (if any) the repairman will require. Generally, the answer is yes, manufacturers may do alterations.

If you are working on your own canopy, I don't think the FAA is interested in what you're doing -- their focus is on protecting the general public, not on protecting you from yourself. If you are working on someone else's canopy, you should have the appropriate certificate (Senior or Master, depending).

Mark

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Mark,
Just a side note:

If, let's say PD made the canopy.
Anything that you change or replace on that canopy will either be a replacement part or a modified part or accessory.

In both cases , you would not still be the manufacturer.

PD would be!

You have to think in airplane terms here.

Cessna. I replace a skin on a fuselage sorta thing.


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

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"I did this not as a rigger, but as an everyday guy who makes things. "

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

You are getting silly!
Once you earn a license, everyone holds you to that higher standard.




I know - it would be a tough case to prove.

There are two venues where I could possibly have to defend myself; civil court for a civil lawsuit seeking money and an FAA investigation. I have differing opinions how the defense would work in each venue, I am not a lawyer, but I do have a pretty good knowledge of the court system from being in the business world.

But again, this thread is not to argue the defense of a court case - and I HOPE TO NEVER HAVE TO BE IN COURT.

HENCE - I am trying to advocate that the FAA rules match reality of what skydivers, manufactures and riggers accept as common practice in the field - and MEL in this very conversation indicated most people are in violation of these rules because they are so unenforced most people do not know they exist!

This thread got people talking and thinking. My biggest concern is that right now there are a few riggers (not me:P) talking to the FAA, and these riggers are advocating things to change in the rigging testing process and other aspects of rigging. I have no way to know what is being said and what is being advocated - however I wonder how much of what is being advocated is coming from the consensus opinion of the PIA, USPA, and community at whole versus a few riggers and DRPEs expressing their goals with FAA employees they befriended.

I will stand firm that:
1) mains have zero manufacturing requirement per the FARs, people like Brian Germain have sewn them in their garage. If I (as a rigger or not) wanted to sew one today - I could. I could sell it. I would not even have to test it before selling it.

Skydivers have always purchased mains on the reputation of the manufacture, and accepted the risks for doing so. AND skydivers I know have their main repaired and altered by people they choose and trust to do so, including themselves.

The community concensus from people I talked to is that the reserve is god - it is highly regulated and in maintained in the world of riggers. The main is more like an experimental aircraft, there are no manufacturing requirements, and it is maintained in the jurisdiction of the skydiver and people he or she trusts.

2) skydivers for years and years from what I have been told, and for as long as I have been in the sport, have been repairing and maintaining and altering their mains.

3) skydivers and riggers I have met have successfully determined what (on the main) is within their skillset and when to refer the work to the factory - such as when a friend of mine replaced his own brake lines with no rating, or when I sent a canopy to PD, even though the repairs were within my skillset and rating as minor repairs (patches) because I wanted a higher quality product due to the size and location of the patch.

4) replacing a lineset or line safely and accurately does not take the skillset of a master rigger (many years in the business and hundreds of packjobs of various types) - I was taught by two (master) riggers how to do it in a few hours. I would never do the repair on a reserve, or even claim I have the experience to modify a container - I respect the fact master riggers have a huge skillset to prove before they start digging into complex projects. However, dumbing down the average skydiver with rigging knowledge and senior riggers to the point they cannot even replace a line on a canopy that had no manufacturing regulations or testing regulations - is just sad in my book.

5) Incident reports show that the commonly accepted practice (which appears to be illegal now) of riggers of various experience levels (the canopy owner, friends of the canopy owner without certs, and Sr. riggers) maintaining, altering, and repairing mains - has not been a safety issue to the general public especially, and not even skydivers. (The general public is what most of the FARs relating to skydiving try to protect)

Hence, I hope the people who are pushing change, pushing revisions, pushing clarity in the rules - take a step back and ask, "we all know the FARs are being broken, and the FARs are not clear in this regard... What is the action plan to bring both aspects to the forefront so the rules match the common industry practice deemed statically safe from incident report history?"

This is my personal opinion, my opinion only... Maybe you agree, maybe you don't.

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You have to think in airplane terms here.



Ok...

Reserve (a parachute with a rigid design, testing, and manufacturing process - TSO - maintained by riggers) is to Cessna (a plane with a rigid design, testing and manufacturing process - maintained by certificated mechanics)

AS A

Main
(a parachute with NO design or testing requirements that can be sewn in a garage and skydivers have altered and repaired for years) is to an experimental plane (an aircraft that can be made in a garage, no certificated mechanic to repair).

DISCLAIMER, I DO NOT KNOW MUCH about experimental aircraft, other than I have been in them and jumped out of them.

However I do know that - there is a HUGE difference between how things are regulated in the design, making, manufacturing, altering and maintaining of aircraft that are experimental and not. My friend with no ratings made his plane from a few preassembled parts and fixes it when it breaks.

So, I thought in terms of aircraft... Does that work???:)
Further thinking of aircraft terms... If I took the front half of a Cessna - and the back half of an otter, and duct taped them together, and did all the flight testing required, had my supply chain regulated for my procurement of "parts", and got the FAA's blessing in a certificate - I could have a whole new plane called a "Cestter". Now I am the manufacture of that "Cestter" and Cessna just became my parts supplier.

But - since there are NO manufacturing requirements for a main - no TSO stamp - no supply chain regulation - I think the argument that I manufactured a new canopy with parts from PD and a new lineset of my design (although lame and inappropriate) would work... Why? Prove to me when the manufacture process stops and altering begins in something that has no regulations in the first place? Prove to me which parts are certificated (TSO) and how I altered something that was TSOed? Again - aircraft and reserves - certified parts have to go on certified systems per the manufactures instructions... Experimental aircraft and mains - recycle, remake, reuse, redesign, substitute, etc...

Mains are not certified. I can call myself a manufacture and simply say I manufacture canopies with modifications to the linesets using off the shelf fabric pre sewn canopies. Yes, again I don't want to be the one pushing the rules or being a rebel - however I am simply trying to express that, it is very difficult to regulate the repair and servicing of something that has no regulation in the manufacturing.

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there is a trend here, ask people who can work on a main, nobody really knows......ask a master rigger, and they will tell you only a master rigger.

Where can I find (in writing) the preamble that people keep telling me spells this out, but never show me? This would be helpful to read

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there is a trend here, ask people who can work on a main, nobody really knows......ask a master rigger, and they will tell you only a master rigger.

Where can I find (in writing) the preamble that people keep telling me spells this out, but never show me? This would be helpful to read



AC 105-2C, section 8: "Parachute alterations are changes to the FAA-approved configuration." Since main parachutes do not have FAA-approved configurations, the changes you make to your main are not, by this definition, alterations.

That conflicts with FAR 65.125(c): "A certificated parachute rigger need not comply with Secs. 65.127 through 65.133 (relating to facilities, equipment, performance standards, records, recent experience, and seal) in packing, maintaining, or altering (if authorized) the main parachute of a dual parachute pack to be used for intentional jumping." The implication is that authorization is required for altering the main parachute.

Confused yet?

A senior rigger may do minor repairs, a master rigger may do major repairs. A major repair is one which, if done improperly, might appreciably affect airworthiness. For harnesses and reserves, the standard of airworthiness is tied to certification tests. For mains, there is no standard for airworthiness, so if you set your standard for airworthiness low enough, any repair is minor.

The guidance commonly used is Poynter's Parachute Manual, and FAA-H-8083-17 (Parachute Rigger Handbook), both of which have tables listing repair limits, and repair procedures that include necessary rigger qualifications. The same repair may change from minor to major depending on proximity to critical components like seams, line attachments, and reinforcing tapes; and the same repair might require a master rigger if it's on a reserve.

Still following along?

The FAA definition of maintenance: "Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance." Using this definition, you need a rigger ticket to do any maintenance beyond preventive maintenance, but you don't need a rigger ticket to do preventive maintenance." From the aircraft world, preventive maintenance includes changing engine oil and airing tires. I think -- my opinion -- changing rubber bands and main closing loops would be preventive maintenance, and I hope your local FSDO is relaxed enough to consider parts exchanges that can be done with elementary operations (swapping one main pilot chute for another one of similar size, for example) as preventive maintenance as well, even though it doesn't fit the strict definition.

Please do not press the FAA to make more exact definitions, and especially do not press them to give examples. The system we have works well to protect the public, and skydivers are not dying because of poor rigging or unauthorized alterations to main parachutes. If you ask a bureaucrat to make changes, the results will be more restrictive.

Finally, I am one master rigger who thinks you should be allowed to do anything you want to your own main, and I would go so far as to say you should be allowed to do anything you want to someone else's main, too, as long as that someone else provides informed consent.

Cheers,
Mark

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I follow, and that is how I thought it was. If the main parachute is not required to be approved than how can it be regulated.

The preamble I refer to is the one that I am always told to read after being told that the intentions of the part 61 statement pack, maintain, alter refers to changing the method of packing the main , and not changes to its construction.

I do agree that I do not wish the FAA to rewrite this part, despite its confusion. If it is rewritten it would no doubt be done so by the FAA in conjunction with manufacturers and master riggers with specific interest, and as a result be overly strict for economic reasons. Mandatory main canopy line replacements done only by factory at specific jump numbers, looking at your main crosseyed warrants a factory inspection, etc.

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The preamble I refer to is the one that I am always told to read after being told that the intentions of the part 61 statement pack, maintain, alter refers to changing the method of packing the main , and not changes to its construction.



Here is where the FAA published the final rule changing Parts 65 and 105. There isn't a specific section called "Preamble," but there is a significant section discussing background, issues, comments, and the FAA's response to the comments.

It doesn't address the issue you raise, so if it's what you were told to read, the tellers have confused their whims with legal requirements.

Mark

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AC 105-2C, section 8: "Parachute alterations are changes to the FAA-approved configuration." Since main parachutes do not have FAA-approved configurations, the changes you make to your main are not, by this definition, alterations.

That conflicts with FAR 65.125(c):



For a moment I thought the AC 105 thing was the thing that would save us from the dreaded FAR 65 "altering (if authorized)" wording.

But I'm not so sure: Don't the Advisory Circulars have less standing than the actual CFR's / FAR's? The FAR's still rule, but AC's attempt to explain and go into more detail about suggested good practices.

The AC 105 section that mentions the quoted text, is one that deals only with approved parachutes. So despite the wording, one gets they idea they are talking about reserves & harnesses only, and not really about mains.

It was a good try, but I'm not confident that the contradiction Mark pointed out, actually gets us out of the need for riggers to alter main parachutes in the USA.

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It was a good try, but I'm not confident that the contradiction Mark pointed out, actually gets us out of the need for riggers to alter main parachutes in the USA.



You're right. "Conflicts with" does not mean "overrules" or "supersedes." It just means the FAA is confused.

Mark

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"I did this not as a rigger, but as an everyday guy who makes things. "

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

You are getting silly!
Once you earn a license, everyone holds you to that higher standard.



And someone hits upon the main reason I still don't have a ticket......:)
----------------------------------------------
You're not as good as you think you are. Seriously.

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Travis,
Here's the bottom line.

A Senior Rigger ia a very basic rigger.
It is easier to spell out what he or she can do than what they cannot do.
It is very limiting.

The FARs have always stated that a Master Rigger is the only one to do alterations and major repairs.

The only mis-cue was when the word alter was entered into 65.111 para(B) 2.


65.129 has not changed.

Several things here:

If you do work outside of your certificate as the FAR state; it would be illegal to do so.

If you want to be legal, simply follow the Senior's certificate with a Masters certificate.

You seem to think something was taken away from you, when in reality it has always been that way from the start.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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