180 Day Repack news

[GrndRush 0]

Technically speaking, a rigger CANNOT pack a reserve if the AAD expires the next day. If the AAD expires prior to next due date (180 days), the AAD must be removed or the reserve cannot be packed.

[Squeak 17]

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Technically speaking, a rigger CANNOT pack a reserve if the AAD expires the next day. If the AAD expires prior to next due date (180 days), the AAD must be removed or the reserve cannot be packed.

Not true
you can short sign the repack due date to before the ADD expiration (at least you can here)

You are not now, nor will you ever be, good enough to not die in this sport (Sparky)
My Life ROCKS!
How's yours doing?

[mark 102]

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Technically speaking, a rigger CANNOT pack a reserve if the AAD expires the next day. If the AAD expires prior to next due date (180 days), the AAD must be removed or the reserve cannot be packed.

That is not true in the U.S. although some riggers have chosen to make it a personal standard.

Legally speaking, a U.S. rigger CAN pack a reserve even if the AAD expires the next day, just as a mechanic can sign off an aircraft annual inspection even if there is known recurring maintenance that needs to be addressed before the next annual. For example, some engines must have the oil changed every 25 hours of operation -- and it is not that mechanic's responsibility to track down the aircraft to ensure the oil gets changed. It's the operator's responsibility to find a mechanic or other qualified person to change the oil.

There is no way for a rigger to ensure that a rig will be airworthy throughout any pack cycle. The rigger is responsible for delivering the rig in a condition safe to jump. The owner is responsible for keeping it that way.

Mark

[rmarshall234 13]

" Then called my FAA FSDOand he opined it was the airman's/parachutist's responsibility if a governmental rule change causes something to "time out". Not the rigger's reposibility, when it was properly legal/in compliance when the work was performed. This is one FAA official's position, and, makes sense to me. "
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Additionally:
Part 91.405 (as listed below) already addresses this issue of something going out of compliance before the next req'd inspection. I see no reason to expect the FAA to treat parachute equipment any different than they do aircraft. The onus is put on the "owner or operator" to make sure the equipment is kept legal and airworthy. I believe this approach is helpful in that if the user is brought in the loop, they will likely become more involved and more educated and that can only be a good thing.

91.405 Maintenance required.
Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service;

(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by §91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard has been installed as required by §43.11 of this chapter

[RIGGER 0]

The rigger is I&R the reserve / h/c for the next 120 days or 180 days based on being safe at the I&R time.

The rigger can not control the rig during use if is still airworthy or not - this is for the owner to take care of or in case of ??? to ask his rigger.

If the AAD / Batt. in that rig will expire before the 120 / 180 days repack cycle the rigger should act:

1. Replace the Batt. at the present repack time.

2. limited the repack cycle to the AAD expiring date if it is before the I&R regular due date.

No way to sign on the rig for 120 / 180 days knowing the AAD will expire out for any reason during that time.

All time the AAD is INSIDE the reserve container it is a part of the reserve repack cycle by all means.

Be Safe !!!

[tdog 0]

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There are more ramifications than that... isn't the pilot technically responsible for the rigs in the plane? Theoretically, could the pilot catch shit for the rig in the loophole I described? Say the jumper goes in during the month of January with said loophole.... that's going to open a can of worms.

I don't know if this is a "loophole"... But yes, the pilot could get in trouble - just as if the pilot had a rig that was out of date on the packjob itself.

I asked SSK some questions via e-mail. They actually sent me this link to an old post to answer my questions... Kind of ironic that it predicts the future in this 2006 post... It answered a lot of questions - and as the manufacturer's opinion, I am keeping it on file.

http://www.dropzone.com/cgi-bin/forum/gforum.cgi?post=2385171;#2385171

[masterrigger1 2]

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and as the manufacturer's opinion, I am keeping it on file.

Travis,
SSK is a service center. Not the manufacturer.

Airtec may have the same opinion, but I cannot find it anywhere in their printed instructions.

I personally will not "shorten" a pack job because:

1. I have never found an FAR that allows me to do so.

2.The potental for the end user to continue to use the rig is very great.

3. If the rig is used past the "shortened" date and the guy goes in; most likely you will be seeing 12 gray haired lady's in the jury box....The lawyer will certainly make sure of it using #1 above as the case.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[tdog 0]

MEL,

I am not saying I am adopting the practice of the post I linked in my last post. I am just keeping it on file... If I adopt it on a case by case basis, or across the board, or not at all - it will be my decision. I posted it to share info, not to advocate...


But - to your three line items:

1. "I never have found an FAR that allows me to do so."

I have never found an FAR that doesn't allow me to do so. Specifically, I have yet to see in writing from the manufacture and/or the service center that they believe a unit with a future battery expiration (any date in the future) is not airworthy to be packed at that moment. I have in fact, the opposite in writing.

Nor have I found a FAR that requires the rigger to certify that the rig will be airworthy for the entire pack cycle referencing the AAD or any other component.

Part 65:

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No person may conduct a parachute operation using a single-harness, dual-parachute system, and no pilot in command of an aircraft may allow any person to conduct a parachute operation from that aircraft using a single-harness, dual-parachute system, unless that system has at least one main parachute, one approved reserve parachute, and one approved single person harness and container that are packed as follows:
(a) ... (Main pack cycle)
(b) ... (Reserve must be packed by rigger)
(1) ... (120 days for synthetic)
(2) ... (60 days for silk)
(c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.

It seems by the FAR that the responsibility to maintain the AAD lays squarely on the jumper and pilot... Since item "C" is a new bullet point, and the preamble does not mention "rigger", "C" doesn't have anything to do with riggers.

2. "The potential for the end user to continue to use the rig is very great."

They could pencil pack it, they could jump it post 120/180 days, they could repack it themselves and buy a seal press with your seal code or jump it unsealed, or do just about anything. Try to tell a jury that the failed packjob was not yours when the last entry on the card was yours... Hence, I personally believe in the "know your customer well before packing" rule.

3. "If the rig is used past the "shortened date" and the guy goes in.

There will have to be some sort of negligence... If the rigger documented the card "don't jump after", and gave the customer a statement in writing, and it was jumped, where was the rigger negligent?

If you are gonna be sued for a frivolous case, you are gonna be sued no matter what you do. I will just bring a bunch of gray haired mechanics and riggers to my case, who the gray haired ladies in the jury box will respect, who will discuss all the time limited components of aircraft that are allowed to remain in use after an officially required inspection that will time out before the next inspection.... They will say this is standard practice in aviation. They will also say they cannot find a FAR or manufacture instructions that require skydivers or riggers to act differently. And they will all say that the rig was presumably airworthy at the time of inspection and pack, that a time limited component was well documented, and the user - not the rigger, was responsible for maintaining the AAD after the repack, per FAR part 65.

Step it up a notch. Have the customer sign your own log book, after writing in their own handwriting, "I understand my AAD batteries will expire on X date and I will not jump the rig."

Again - I am not saying what I am GONNA do for one or all of my customers, just arguing a point that people with different opinions believe.

[masterrigger1 2]

Travis,
We have been down this road before and you have your opinion as well as I have mine...and they are different.


1. "I never have found an FAR that allows me to do so."

I have never found an FAR that doesn't allow me to do so. Specifically, I have yet to see in writing from the manufacture and/or the service center that they believe a unit with a future battery expiration (any date in the future) is not airworthy to be packed at that moment. ....

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The FAR part 65 list rigger's privileges, Things that the rigger is allow to do, not things that he can't do!

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

and then there are the performance standards:

§ 65.129 Performance standards.
top
No certificated parachute rigger may—
........

and finally records:

65.131 Records.
top
(a) Each certificated parachute rigger shall keep a record of the packing, maintenance, and alteration of parachutes performed or supervised by him. He shall keep in that record, with respect to each parachute worked on, a statement of—

(1) Its type and make;

(2) Its serial number;

(3) The name and address of its owner;

(4) The kind and extent of the work performed;

(5) The date when and place where the work was performed; and

(6) The results of any drop tests made with it.

(b) Each person who makes a record under paragraph (a) of this section shall keep it for at least 2 years after the date it is made.

(c) Each certificated parachute rigger who packs a parachute shall write, on the parachute packing record attached to the parachute, the date and place of the packing and a notation of any defects he finds on inspection. He shall sign that record with his name and the number of his certificate.

________________________________________

It is pretty much spelled out for you there.

.......I have in fact, the opposite in writing.

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Again from whom? The manufacturer or the Service Center?

2. "The potential for the end user to continue to use the rig is very great."

They could pencil pack it, they could jump it post 120/180 days, they could repack it themselves and buy a seal press with your seal code or jump it unsealed, or do just about anything. Try to tell a jury that the failed packjob was not yours when the last entry on the card was yours... Hence, I personally believe in the "know your customer well before packing" rule.

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If they pencil packed it, it would be easy to prove that you did not pack it. You would have no record of it in your logbook. (and no sales invoice, at least for me anyway).
Then finally it would be outside of the 120-180 days(pick one), which release you legally.

Again - I am not saying what I am GONNA do for one or all of my customers, just arguing a point that people with different opinions believe.
***

Exactly!

The FAR's are being "dressed up" for better interpretation purposes right now.
I think this also needs to be looked at before they finish.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[tdog 0]

Yes our opinions are different.

I still don't see reference to battery changes and future airworthiness guarantees by a rigger at the time of packing in the FARs you quote???

I agree, there is no reference to recording future lifetime expirations in the FARs. I believe one would do this, but not required to do this, to cover ones butt and to inform their customer of their responsibilities.

But at least both opinions have been expressed.

[riggerpaul 1]

From the last 3 posts I get the feeling that there is a little misunderstanding between tdog and mel about who is claiming what.

mel said it is not legal to repack a rig when a component lifetime will expire during the repack interval.

tdog said that is appears to be legal to repack a rig even though a component will expire within the repack interval.

Somebody, not tdog, mentioned changing the repack date to "solve" the problem.

mel said that he never saw a regulation that allowed him to use a date other than the date of the inspection. That is, he said he didn't see a regulation that allowed him to alter the apparent repack "expiration".

So, I sort of see 2 different discussions going on. One is about messing with the repack date, and the other is about when we can legally repack a rig.

I agree with mel that we cannot mess with the date.

I agree with tdog that we can repack even though the AAD battery will expire within the repack interval.

So, mel, can you show us how the regulations say we cannot repack when the battery will expire during the repack interval?

[masterrigger1 2]

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I agree with tdog that we can repack even though the AAD battery will expire within the repack interval.

So, mel, can you show us how the regulations say we cannot repack when the battery will expire during the repack interval?

Of course I disagree with the first sentence. As far as the last part, I think the answer lies in performance standards.

§ 65.129 Performance standards.
top
No certificated parachute rigger may—

(a) Pack, maintain, or alter any parachute unless he is rated for that type;

(b) Pack a parachute that is not safe for emergency use;

(c) Pack a parachute that has not been thoroughly dried and aired;

(d) Alter a parachute in a manner that is not specifically authorized by the Administrator or the manufacturer;

(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute; or

(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has—

(1) Performed duties under his certificate for at least 90 days within the preceding 12 months; or

(2) Shown the Administrator that he is able to perform those duties.
_____________________________________________

I think (e) is where the answer lies. Also remember that the FAA dictates the pack intervals, not the manufacturer when reading that sub-part.

You also have to remember that when the FAR's were first developed, the pack intervals were only 15 days.

........then 30, 60,120. and now coming is 180.

IMHO, the intent the FAR's wants the parachute system (at the time of sealing) to be ABLE to make the complete cycle. Of course things happen that make the system non-airworthy from time to time, but I think that is another discussion.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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IMHO, the intent the FAR's wants the parachute system (at the time of sealing) to be ABLE to make the complete cycle. Of course things happen that make the system non-airworthy from time to time, but I think that is another discussion.

BS,
MEL

That's a different standard than for aircraft and aircraft mechanics. What is the evidence that the FAA intends to treat them differently?

Mark

[riggerpaul 1]

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I agree with tdog that we can repack even though the AAD battery will expire within the repack interval.

So, mel, can you show us how the regulations say we cannot repack when the battery will expire during the repack interval?

Of course I disagree with the first sentence. As far as the last part, I think the answer lies in performance standards.

§ 65.129 Performance standards.
top
No certificated parachute rigger may—

(a) Pack, maintain, or alter any parachute unless he is rated for that type;

(b) Pack a parachute that is not safe for emergency use;

(c) Pack a parachute that has not been thoroughly dried and aired;

(d) Alter a parachute in a manner that is not specifically authorized by the Administrator or the manufacturer;

(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute; or

(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has—

(1) Performed duties under his certificate for at least 90 days within the preceding 12 months; or

(2) Shown the Administrator that he is able to perform those duties.
_____________________________________________

I think (e) is where the answer lies. Also remember that the FAA dictates the pack intervals, not the manufacturer when reading that sub-part.

You also have to remember that when the FAR's were first developed, the pack intervals were only 15 days.

........then 30, 60,120. and now coming is 180.

IMHO, the intent the FAR's wants the parachute system (at the time of sealing) to be ABLE to make the complete cycle. Of course things happen that make the system non-airworthy from time to time, but I think that is another discussion.

BS,
MEL

Thank you MEL. I appreciate your help.

(e) above does not actually say that the equipment must stay legal through the repack interval. What it says is that I should be able to find documentation regarding "procedures approved by the Administrator or the manufacturer of the parachute" to give us guidance in this area.

I only know of AC 105-2c as an additional source of procedures approved by the administrator. If there is another I should check, please let me know.

I found nothing in AC 105-2c that says all the components must stay legal through the inspection interval.

I also carefully checked the CYPRES User's Guide. The only thing is says is that batteries must be replaced if: 1) the low battery codes are displayed on power up, 2) after 500 jumps, and 3) after 2 years.

So, at this point, I still don't see anything that actually tells us not to repack a rig when the AAD battery will expire within the inspection interval.

By the way, the 500 jump limitation is also a problem for your premise that the rig should make it through the repack interval. There is absolutely no way for a rigger to act on this restriction; the jumper himself is the only one who can make anything close to a meaningful decision in that regard. I don't think anybody ever refused to repack a rig with an in-date battery because he thought that the 500 jump limit would be reached during the repack interval. Do you? I regard this as precedent setting, even though our community has never had the disagreement on this issue that we are exploring now.

The way I see it, what you are saying is that we, the riggers, should tell a jumper that he cannot jump his rig today even though all the components are legally allowed to be used. I don't think we have that privilege or responsibility.

There have been many related discussion on dz.com over the years regarding questions like "can a rigger ground a rig" and things like that. I believe the final word on that one was that while any rigger can refuse to repack a rig for any reason, he is not given the authority to actually ground a rig.

There is ample precedent in aviation law that an inspection does not say that everything stays legal throughout the inspection interval. The classic example of the ELT battery is a great one since it deals with the identical issue as applied to an aircraft. Actually, I think it is a better example than the AAD to show that the FAA does not expect component life to limit an inspection. An ELT is required equipment, and AAD is not. If your A&P says he will not sign off on an annual because your ELT battery will expire in 11 months, you go find another A&P.

Why should the AAD battery be treated differently?

[rmarshall234 13]

>>There is ample precedent in aviation law that an inspection does not say that everything stays legal throughout the inspection interval. The classic example of the ELT battery is a great one since it deals with the identical issue as applied to an aircraft. Actually, I think it is a better example than the AAD to show that the FAA does not expect component life to limit an inspection. An ELT is required equipment, and AAD is not. If your A&P says he will not sign off on an annual because your ELT battery will expire in 11 months, you go find another A&P.

Why should the AAD battery be treated differently?
---------------------------------------------------------

Exactly. Thank you.

(Another example would be not signing off an annual inspection because the Transponder certification will come due within the next 12 months.)

The signature at repack time signifies that the rig is in an airworthy condition at that time. It then becomes the owner or operator's responsibility to make sure it stays that way when in use.

[masterrigger1 2]

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Why should the AAD battery be treated differently?

Paul and Mark,

The difference is this.
The ELT scenario is covered with written policy and guidance by the FAA to be replaced as neccesary.

The AAD scenario has no written allowances!

I guess I should have pointed that out earlier.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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Why should the AAD battery be treated differently?

Paul and Mark,

The difference is this.
The ELT scenario is covered with written policy and guidance by the FAA to be replaced as neccesary.

The AAD scenario has no written allowances!

I guess I should have pointed that out earlier.

BS,
MEL

The AAD scenario has no specific written policy or guidance either way. All we have are analogous situations from the aircraft world, every one of which supports the idea that we must deliver an airworthy rig to our customer, but it is the customer's responsibility to keep it airworthy, including returning if for service on a periodic or as-needed basis.

Mark

[masterrigger1 2]

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The AAD scenario has no specific written policy or guidance either way.

Mark,
I believe it to be here.
http://www.faa.gov/library/manuals/examiners_inspectors/8300/
If not I will find it later for you...setting up for the Family Dinner tomorrow!!!

BS,
MEL

PS: Also look in CAR Part 07. I believe there to be some mention in there also.

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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The AAD scenario has no specific written policy or guidance either way.

Mark,
I believe it to be here.
http://www.faa.gov/library/manuals/examiners_inspectors/8300/
If not I will find it later for you...setting up for the Family Dinner tomorrow!!!

BS,
MEL

PS: Also look in CAR Part 07. I believe there to be some mention in there also.

The url you provided resolves to FSIMS, which makes sense since inspector handbook 8300.10 has been incorporated into FSIMS. No mention of AADs there that I could find except for the procedure for alteration approval for installation.

Do you have a url or other reference for CAR Part 07? I couldn't find it, either.

When you have time, could you provide the specific citation and quote?

Mark

[masterrigger1 2]

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....No mention of AADs there that I could find

Mark,
I was speaking of the ELT allowance, i.e. if the battery was to be due before the next annual.

Here is a link to a power point presentation that describes the responsiblities of the aircraft owner.

The aircraft owner/operator is different to a skydiver. The aircraft owner usually has a certificate, either a Part 135 or pilot's certificate to which he is held accountable for....and could lose if the rules are violated.

file:///C:/Documents%20and%20Settings/Mark%20Lancaster/Local%20Settings/Temporary%20Internet%20Files/Content.IE5/OTIR8DJ2/pltmec%5B1%5D.ppt#294,39,QUESTIONS

If you look hard enough you will find the info you need to verify that there is indeed written policys and guidance to allow the ELT battery to be used with a short life.

Here are some references for the ELT:

FAR Part 91.207(c)1+2 and (d)1 though 4
TSO - 91
FAR 21.305
Notice A 8310.1
AC91-44A
14 part 43
AC 43.13-1
Part 39

You will not find the same written allowances or guidance for the AAD batteries.

Also, I was talking to Dave Dewolf earilier. He reminded me of the meeting at the last PIA meeting which included several top FAA people.
In that meeting, questions regarding the following were asked:

(as best as I remember)

1. "Can one shorten a pack job to reflect battery life or any other reason?"
Their response was "NO".

2. Can a rigger open a container, perform a service to the rig, then simply re-close and re-seal the parachute.
Their response was "No,if the parachute is opened it must go though the complete 120 day inspection and repack".

......Again not in probably their exact words, but pretty close.

I am sure this will come up again at the PIA meeting,
so ask them about this again.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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I was talking to Dave Dewolf earilier. He reminded me of the meeting at the last PIA meeting which included several top FAA people.
In that meeting, questions regarding the following were asked:

(as best as I remember)

1. "Can one shorten a pack job to reflect battery life or any other reason?"
Their response was "NO".

2. Can a rigger open a container, perform a service to the rig, then simply re-close and re-seal the parachute.
Their response was "No,if the parachute is opened it must go though the complete 120 day inspection and repack".

......Again not in probably their exact words, but pretty close.

I am sure this will come up again at the PIA meeting,
so ask them about this again.

BS,
MEL

What regulation(s) did the FAA folks cite?

Mark

[riggerpaul 1]

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(as best as I remember)

1. "Can one shorten a pack job to reflect battery life or any other reason?"
Their response was "NO".

2. Can a rigger open a container, perform a service to the rig, then simply re-close and re-seal the parachute.
Their response was "No,if the parachute is opened it must go though the complete 120 day inspection and repack".

......Again not in probably their exact words, but pretty close.

Neither of your anecdotes speak directly to the issue of all components being legal until the next inspection.

Anecdote #1 says only that we must faithfully record the date of the inspection.

Anecdote #2 says only that if the rig is opened, it must be inspected and repacked.

If the FAA is at the Symposium to discuss matters and questions, then it is important that we ask the correct question.

The correct question to ask would be something like "can we inspect and repack a rig if the AAD battery will expire before the next inspection?". That's the question that we want answered.

If they say, "no, you cannot", then the next question should be "what regulation sets forth that requirement?".

They should be ready to back up their statements with referenced in the FARs. If they cannot state the regulation that sets forth the requirement, then their assertion is suspect.

I will be happy to accept the law as you tell me it exists when someone shows me written regulations that support that position.

For now, I want to ask you how you, personally, handle the 500 jump limit on a CYPRES (1) battery. If the regulations say that all components must make it to the next inspection, how do you, personally, enforce the 500 jump limitation? Do you ignore it? Do you insist that the battery be changed because you are sure it will have reached the 500 limit during the interval? If you do not change the battery, please explain why you don't think you must.

[steelyeye 0]

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Besides, I have an over-active sense of responsibility.

And that, in a nutshell, is why I would trust you to be my rigger.

"Better a has-been than a never-was. Better a never-was than a never-tried-to-be..."

[masterrigger1 2]

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Neither of your anecdotes speak directly to the issue of all components being legal until the next inspection.

[tdog 0]

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I have sent a request to AFS-350 regarding exactly that for you.
So it should be forth coming pretty soon.

Would you mind sharing with us what you sent, maybe the text from your request?