180 Day Repack news

[masterrigger1 2]

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But if you read it that literally, then you can't even reseal the rig if the seal gets broken.

Dave Dewolf has always had the opinion, "broken seal, New pack job"! And who here on DZ, has been rigging longer than him?

And the FAR's have to be taken literally. Federal law and regulations are written to be that way.

Merry Christmas,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[pilotdave 0]

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And the FAR's have to be taken literally.

I totally disagree. The FARs are poorly written. They must be interpreted, not taken literally. Only the FAA gets the final say in the interpretation. Sometimes they use ACs to interpret FARs, sometimes they publish letters of interpretation.

If you take that FAR literally, there is no requirement to reseal a rig after maintenance has been done or if the seal breaks. A seal is only required after the rig is packed. Nothing stops a jumper from breaking the seal off and continuing to jump the rig legally. Right?

Dave

[peregrinerose 0]

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But if you read it that literally, then you can't even reseal the rig if the seal gets broken.

Dave Dewolf has always had the opinion, "broken seal, New pack job"! And who here on DZ, has been rigging longer than him?

And the FAR's have to be taken literally. Federal law and regulations are written to be that way.

Merry Christmas,
MEL

That's only true if you don't know where the rig has been and how the seal was broken. If you are working with a student, who inadvertently breaks a seal, right in front of you, would you do a full repack? I wouldn't... I'd use it as a teaching tool for the student, reseal the rig, and move on. But according to your interpretation, that isn't possible.

Do or do not, there is no try -Yoda

[riggerpaul 1]

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§ 65.133 Seal.
top
Each certificated parachute rigger must have a seal with an identifying mark prescribed by the Administrator, and a seal press. After packing a parachute he shall seal the pack with his seal in accordance with the manufacturer's recommendation for that type of parachute.

This reg is cut and dry/black and white and leaves no doubt that you must pack a parachute to seal it.

But if you read it that literally, then you can't even reseal the rig if the seal gets broken.

Do you inspect/pack the reserve if a rig you just packed last week comes back to you with a broken seal since it must be sealed only after packing it?

Anyway, yes, I do seal the rig after packing it. I also seal the rig if the seal gets broken. And the seal can get broken just from normal use or from myself when having to put a new ripcord in, or service an AAD, or the like, within the same repack cycle.

I understand how you are interpreting the reg...just not convinced we have to take it that literally. But, you could be right...we'll see...

Mike

The way I read that rule, if I was that last one to pack that parachute, it is "after packing".

The rule doesn't say anything about how long after.

The other thing I get from that rule is that someone should not seal it if he did not do the most recent packing.

Taken literally, "after" does not stipulate "immediately after". If they wanted to say "immediately after", it would have been a simple matter to say that instead.

[jerm 0]

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Mike,
Do you repack the parachute if you service the AAD? The below regulation states that a seal is to be placed on the parachute only after packing it .

if you want to get really pedantically literal about it, it doesn't say only immediately after packing it... it only says after packing it. In fact, by the letter of the law you're clinging so seemingly literally to, as long as I've packed that rig at ANY point in the past, i can seal it.

This is, of course, absurd. It's quite clear that the intention and interpretation of that poorly written regulation means that only if i was the most recent person to pack it, may i seal it.

You interpret it more narrowly saying that it only counts if done immediately after a repack, but that's not literally what the reg says, that's your interpretation.

If i open my packjob to replace a battery, and reseal it, i'm still dealing it after i packed it... it may be 3 months after i packed it, but by the letter of the law, that's allowable.

Did i pack it(last)? yes. Is it airworthy? yes... why can't i seal?

I can understand the thinking for broken seals. As much as you trust a customer, once the rig has left your possession, you can never really know if the packjob under the hood is still yours. If i'm the one breaking my own seal for maintenance though, why is my new seal any less good than the one that was just on there?

Landing without injury is not necessarily evidence that you didn't fuck up... it just means you got away with it this time

[lonelymoose 0]

I sure wish I could be at Dewolf's class this year to hear the comments/lessons surrounding these issues. There could be some good discussion with all that experience there!

[masterrigger1 2]

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If i'm the one breaking my own seal for maintenance though, why is my new seal any less good than the one that was just on there?

That's simple.

It would have been sealed after maintenance, not packing!
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[jerm 0]

I packed it earlier. Therefore it's getting sealed after i packed it. Why is it that in one sentence you're talking about how the regs are conctrete and literal but then in the next start inserting meaning that doesn't exist in the language of the reg?

Again, why is my seal any less valid after putting a battery in is it's all my work? It IS after i packed it, and the reg doesn't prohibit it.

Landing without injury is not necessarily evidence that you didn't fuck up... it just means you got away with it this time

[pilotdave 0]

I see the requirement to seal a rig after it gets packed. I'll even assume they mean RIGHT after it gets packed. I don't see any other requirements for sealing a rig or not sealing a rig. Where does it say that a rig cannot be sealed at other times? Where does it say that a rig is not airworthy without a seal? You aren't reading the FARs literally. You are interpreting them to the best of your ability (and you may be correct). But the USPA and PIA apparently disagree with your interpretation after speaking with the FAA.

Don't say you're reading the FARs literally and everybody else is making things up. You're jumping to as many conclusions about the FARs as anybody else.

Dave

[masterrigger1 2]

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I packed it earlier. Therefore it's getting sealed after i packed it. Why is it that in one sentence you're talking about how the regs are conctrete and literal but then in the next start inserting meaning that doesn't exist in the language of the reg?

Again, why is my seal any less valid after putting a battery in is it's all my work? It IS after i packed it, and the reg doesn't prohibit it.

Ok...you pack it earlier...sealed it ....then you maintained it....and then sealed it again.
therefore you sealed after you maintained it, not after you packed it.

Pretty clear to me!

The intent of the rule is what gets you, think about it!

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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But the USPA and PIA apparently disagree with your interpretation after speaking with the FAA.

Actually, they never asked any questions regarding issues pertaining to opening and closing reserves.This is according to Ed Averman at AFS-350.

1. USPA never stated that it was OK to open and close reserves.

2. PIA stated that is it was. But remember this, Cliff Schmucker is President of PIA and most likely wrote the notice that is posted on their web site.

3.Cliff Schmucker is part owner of SSK. SSK is a service center for Airtec.

If one were to connect the dots....well there you are!

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Don't say you're reading the FARs literally and everybody else is making things up. You're jumping to as many conclusions about the FARs as anybody else.

Dave,
I can assure you that these are not just my conclusions. There are a lot of people involved in these readings.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[howardwhite 3]

The attached National Policy Notice was posted today on the PIA web site.
Note that in addition to affirming the joint PIA/USPA guidance statements, it specifically mentions AAD batteries.

HW

[masterrigger1 2]

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The attached National Policy Notice was posted today on the PIA web site.
Note that in addition to affirming the joint PIA/USPA guidance statements, it specifically mentions AAD batteries.

HW

That seems to just reflect the "Changeover" period.
I know that they are still writting a final guidance.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[Andrewwhyte 1]

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If the battery pack due date is before the repack due date, the battery pack still has to be replaced on schedule.

It most specifically does not say that the rig must not be packed until the battery pack is replaced.

[riggerpaul 1]

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The attached National Policy Notice was posted today on the PIA web site.
Note that in addition to affirming the joint PIA/USPA guidance statements, it specifically mentions AAD batteries.

HW

That seems to just reflect the "Changeover" period.
I know that they are still writting a final guidance.

MEL

Here's the pertinent text from the National Policy Notice.

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Note:
The amended rule makes no changes regarding the Automatic Activation Device (AAD). If the battery replacement due date is before the repack due date, the battery pack still has to be replaced on schedule.

Even I have to admit that this National Policy Notice still does not directly answer the question, "Can I close a rig if the battery will expire before the next required inspection".

However, neither did they say that such a rig must be removed from service from December 19th 2008 until the battery is replaced.

If the final guidance was going to say that you may not close such a rig, I would have expected the guidance at this time to say that such a rig was not legal to jump until the battery had been replaced.

After all, they know what the conflicting positions are. And all they continue to say is that there is no change.

This policy says the rig whose 120-day inspection had expired may be returned to service until the previous repack is more than 180 days ago.

It didn't say that it could be returned to service only if the battery will make it to the next inspection.

Also, if the rig was not legal to jump, then why say that we must replace the battery "on schedule"?

So, we now have a written document from the FAA that says you can still jump a rig even though the AAD battery will expire before the next inspection is required.

MEL, do you agree that this policy says that?

I am still guardedly optimistic that the final guidance will say that the AAD battery is like an ELT battery, which is already handled the way many of us think an AAD battery should be handled.

[howardwhite 3]

PIA has published on its website today a new version of its FAQ on the 180-day repack cycle. (attached)
It has been "blessed"by AFS-300 at FAA.
Note that it includes a new, seventh question dealing with the issue of opening and resealing a reserve or e-rig between repacks.

HW

[masterrigger1 2]

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It has been "blessed"by AFS-300 at FAA.

That's really funny as the petition was sent to Regulatory and Compliance and I heard yesterday that they are still working it.

Go figure! We still need a FAA document, not a second or third party.

I find it hard to believe that the FAA would base law on "common" practice.

If that were the case, pencil packing would be legal FCOL.

I will call R&C tomorrow and get the scoop...

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

Because I am so anal, I just visited the PIA website with the intention of downloading the document "from the horses mouth" as it were.

I was unable to locate your document on the PIA website, though I can still see the earlier version.

Can you please post the actual link to the document on the PIA website?

[howardwhite 3]

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Can you please post the actual link to the document on the PIA website?

Gladly:
http://www.pia.com/ANNOUNCEMENTS.htm
Top item on the list.

HW

[riggerpaul 1]

Thanks! Silly me, I was looking in the "Public Documents" area.

[howardwhite 3]

PIA today published on its website a new Technical Bulletin (also attached here) which addresses issues of maintenance of sealed parachutes between regular repacks.
Riggers (and skydivers) may find it of interest.

HW
(reporting in from Reno)

[PhreeZone 14]

Looks like PIA is going with the years of field experience and precedence on the recommendation that if a closing loop needs adjusted or AAD batteries need replaced mid pack cycle then it is perfectly fine to just do that maintenance instead of needing a full repack at that time.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[pchapman 261]

I like the common sense approach that mid cycle open & recloses are OK.


But it says, "The rigger who reseals the container is responsible for the airworthiness of the parachute system at the time it is returned to service."

One may just have to ignore that and accept the risk, if one thinks (as I do) that the concept is B.S. An aircraft mechanic who is asked to inspect the spark plugs only can't know if the elevator cable is fraying and shouldn't be held responsible for the airworthiness of the entire aircraft.

If there were a problem with a mid cycle reclose, I'd just argue, "Yes I'm responsible, but obviously in this context it means that I can only be responsible for the things that I can see during the open & reclose. I can't be responsible inspecting things that are invisible, duh!"

Whether or not one buys into what may be an illogical extreme, it still suggests that one must inspect the things one can inspect.

So for an open & reclose, one must budget for a full external inspection of the rig.

It wouldn't be an excuse to say, "I didn't look for or find the broken harness stitching, as my customer specifically asked me to replace the cypres battery and not to waste his money on anything else."

Riggers will probably just continue to do or not do open & reclose jobs according to their personal preference.

[riggerpaul 1]

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But it says, "The rigger who reseals the container is responsible for the airworthiness of the parachute system at the time it is returned to service."

One may just have to ignore that and accept the risk, if one thinks (as I do) that the concept is B.S. An aircraft mechanic who is asked to inspect the spark plugs only can't know if the elevator cable is fraying and shouldn't be held responsible for the airworthiness of the entire aircraft.

It is not a new thing that sealing a parachute requires that we certify airworthiness.

FAR 65.125(b) states that a parachute rigger may not "Pack a parachute that is not safe for emergency use;"

Now, I suppose we can argue about what is or is not "packing a parachute".

For me, if I seal that parachute, I am taking on the taking on the responsibility for its airworthiness at that moment.

To this end, I prefer not to do a mid-cycle maintenance on a parachute that I was not the last person to give a full inspection. I will also check that nothing heinous has happened to the rig. Since I knew at the prior inspection that the mid-cycle work would be needed, I also prefer to keep in close contact with the owner so that I will be aware of any unusual events concerning the rig.

Yes, all this means that I am quite restrictive when I choose to do mid-cycle maintenance.

None of my customers seem to mind my keeping close watch for this purpose. None have objected when I sometimes say that I prefer to do a full I&R. This is especially true when the mid-cycle maintenance is nearer the end of the inspection cycle, when they often prefer to do the maintenance now rather than have an additional disruption shortly later.