180 Day Repack news

[SStewart 13]

Hi Mel,

If I am not mistaken the battery requirement and service for AAD's should still take presidence over any changes in FAA repack cycles. I believe Dave agrees with this.

The paperwork is what will get weird on this. Any rig without electronics should not be affected. (which is not many these days)

Scott

[councilman24 36]

Paper work won't be any different than now. Just more rigs affected.

If a rigger chooses to pre date a pack job to make it expire sooner they still can. (Irregadless of whether they should or not)

If a rigger chooses to not pack a rig with the AAD service or battery that will expire they still can. It will just mean earlier service on more rigs or less business for them.

If a rigger chooses to pack anything current that day no matter when a component may time out they still can do that.

Choices or options haven't changed, the lack of clear guidance hasn't changed, and the varying opinions of people haven't changed.

The debate now is no different than the debate before. Just more rigs affected.

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

[SStewart 13]

>>>>Paper work won't be any different than now. Just more rigs affected.


I think I said the same thing, you just said it differently. No worries, it is common to argue with people who agree with me.

Onward and Upward!

[AllisonH 0]

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News update!

I received this email this AM from AFS-350 (washington). The FAA stance is totally different from what I was previously informed it to be, but seems to be for the better.

Quote

Mark,

The way the rule is written the 180 days starts with the date of the last
repack.

Example, if you have a parachute that hits the current 120 days on December
15 you can not jump the parachute on the 16th, 17th and 18th, but can go
back to jumping the parachute on the 19th when the new rule goes into
effect until is reaches 180 days.

So there you have it!

Cheers,
MEL

I e-mailed Skydive Arizona today to check their interpretation of this. I asked "Will the new 180 day repack cycle be in use at the boogie? (i.e. will my reserve that was packed on August 1 be in date Dec. 26-30? or do I need to get it repacked before I come?)"

The reply I received was "The 180 day repack cycle is set to go into effect December 19th but does not cover reserves packed prior to that date. So your reserve will need to be repacked prior to your arrival to Skydive Arizona."

Not trying to start any arguments, just giving a heads up to anyone else in my situation who may be headed there this month.

[MakeItHappen 15]

Quote

I e-mailed Skydive Arizona today to check their interpretation of this. I asked "Will the new 180 day repack cycle be in use at the boogie? (i.e. will my reserve that was packed on August 1 be in date Dec. 26-30? or do I need to get it repacked before I come?)"

The reply I received was "The 180 day repack cycle is set to go into effect December 19th but does not cover reserves packed prior to that date. So your reserve will need to be repacked prior to your arrival to Skydive Arizona."

Not trying to start any arguments, just giving a heads up to anyone else in my situation who may be headed there this month.

Actually, PIA and USPA will be meeting with the FAA shortly (don't know when) to get a clarification on this.
Standby to standby.

.

.
Make It Happen
Parachute History
DiveMaker

[councilman24 36]

They already met, unless they're going to meet again. After the meeting was when the retroactive email came out. May or may not be related.

But, if you want to get on an airplane check with the people with the keys. As above.

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

[MakeItHappen 15]

Quote

They already met, unless they're going to meet again.

I was told on Nov 28 that they were going to get together again (probably by phone) to clear up this and some other Qs.
So I *think* there is another meeting planned soon.

.

.
Make It Happen
Parachute History
DiveMaker

[masterrigger1 2]

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So I *think* there is another meeting planned soon.

Quote

That's what I hear also! I'm hearing early next week.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[howardwhite 2]

I think the only face-to-face meeting on this among FAA, PIA and USPA was held Nov. 19, the same day the change was published.
According to the USPA blog and other sources, the FAA is working to resolve the remaining questions and will, one hopes, issue clarifications before Dec. 19.

HW

[masterrigger1 2]

Quote

According to the USPA blog and other sources, the FAA is working to resolve the remaining questions and will, one hopes, issue clarifications before Dec. 19.

Howard,
I have been the receipent of some emails that point to possible clarification before the 19th on a couple of different issues.

We will have to wait and see I guess.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[councilman24 36]

MEL,

What method does the FAA have to distribute clarification or guidance on a published rule, other than Advisory Circulars? IF they chose to, how would the FAA distribute such clarification? Through the federal register? Though letters to all riggers? (I can't remember if I've ever gotten something other than an AD by mail. The ATF sends out news letters to FFL holders.) Through press releases?

Just wondering what mechanism, other then second hand 'I got an email' posts by you, that they have or would use. I'm not familiar with what they can do FAST that will get to all riggers, pilots and DZ's as well as field inspectors, all of whom need to interpret the rule.

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

[masterrigger1 2]

Terry,
They do not have a system to notify us.

That's the problem!

I did ask the 350 office (if and when they decide) to put their rules into written form on AC-105-2C regarding these issues for us.\

To include these on the AC requires little to no effort on their part and would be the fastest way possible other than an emergency AD.

I have not received a response from them yet.

I also emailed Allen for information. No response there either!


Another way would be to let USPA, USPA DZs, and PIA be the focal points for distribution of a formal letter from the FAA.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[ZigZagMarquis 8]

http://edocket.access.gpo.gov/2008/pdf/E8-27459.pdf

[councilman24 36]

And your point? This is what the whole thread has been discussing and apparently the feds can't decide how to interpret.

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

[kuai43 7]

This is not hard, people. The FAA isn't bringing into question the METHODOLOGY of packing either main or reserve parachutes. They are simply accepting and ruling that a 180 day cycle is adequate for synthetic materials with current packing methods.

Therefore, the language of the ruling is clear - a parachute packed within the 180 days prior to the effective date of the ruling is legally jumpable. Any other conclusion is based on the illogicial assumption that the same pack job performed on Dec. 19th, and will then be safe for 180 days, would not be safe if it was packed by the SAME rigger with the SAME methods a day before that.

It's not a question of 'grand-fathering' a pack job, just re-categorizing it. Simply read the language of the ruling.

Every fight is a food fight if you're a cannibal

Goodness is something to be chosen. When a man cannot choose, he ceases to be a man. - Anthony Burgess

[riggerpaul 1]

Here's what I believe is a synopsis of the current discussion in this thread.

Actually the issue of "grandfathering" has been pretty well closed. MEL had a post about it some time back, and it is as you say. There will be some parachutes that are not legal to jump for a few days if they were packed more than 120 days prior to the effective date of the rule change. Then they become legal again for the remainder of the new 180 day interval.

There are some side questions that are also being discussed as a result of the new ruling. These side questions are the current focus of the thread. Maybe new threads would have been appropriate, but for now, their home is still this thread.

The first has to do with the question of packing a rig if the AAD battery will expire before the next repack is due. This will impact us by possibly making us put in new batteries up to 180 earlier than the actual battery expiration date. In the case of a CYPRES (1) battery, this is up to 25% of the useful life of the battery. Some riggers feel that they are not allowed to I&R a rig unless all the components will remain legal through the entire repack interval. Others do not fee the same way.

The second has to do with the question of opening and closing a rig without doing a full I&R. This question comes into play if we are allowed to repack a rig with a battery that will expire before the next repack is due. Some riggers feel that the regulation only states when an inspection must have been performed, and it is legal to open and close a rig without doing all the work of a full I&R. Others say that if we open the rig, we must do a full inspection. This would mean that we could not change the AAD battery without doing a full repack. This discussion is a bit more academic than the first, as the closer you are getting to needing a full inspection in the first place, the less likely that anyone will be unhappy with doing one early. Likewise, if the batteries are due in 3 weeks and not 5.5 months, replacing them is less objectionable.

Both these questions have been addressed with anecdotal evidence, but to date, no reference to actual written regulations have surfaced,

MEL has made inquiries regarding these questions, and we are awaiting his posting the answers he gets.

[councilman24 36]

And many of those dealing with the FAA have been told pack jobs before Dec 19 are 120 days.

Even if the reading is clear, that doesn't mean that's what the faa means, intends, or will enforce.

Even with the way the new rule is written most expected that 'old' pack jobs wouldn't be good for 180 days. The feds saying they were was a surprise. Now there is 3rd hand info they may be reversing themselves.

All that matters is will a DZO let you on the airplane and will they get busted for it.

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

[jojo0815 0]

Hey guys, I really don't understand all the confusion. The FAA couldn't have made this any simpler. What I really don't understand is the reply from Skydive Arizona, they are simply wrong. I emailed the FAA to clear this up last week. I figured hearing it from them I can then educate my customers correctly. Here it is:

" The way the rule is written all sport, emergency and reserve parachutes automatically to 180 days on December the 19th.

Say the 120 days is December 19th the repack is extended to February 17th.

If a parachute reaches the 120 days on December 15th it would be a violation to jump that parachute on the 16th, 17th, or 18th of December. But when the new rule goes into effect you can go back to jumping the parachute on the 18th of December and its repack date becomes the 13th of February.

This rule makes no changes with the AAD's. Say the battery come due before the repack is due it still has to be replace on schedule.

91.307 (a)(1) and 105.43 (a) were changed to take the repack for the mains to 180 day. The 180 days does apply to tandem parachutes. 105.45 (b)(2) states you have to repack the reserve parachute used in a tandem system in accordance with 105.42 (b) which is 180 days."

[ozzy13 0]

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The first has to do with the question of packing a rig if the AAD battery will expire before the next repack is due.

My question is: What was the rule for the 120 cycle?

I would think it would be the some for the 180 day cycle.

Why is this so difficult for people.

Never give the gates up and always trust your rears!

[riggerpaul 1]

The issue has been unclear for a long time. It is just coming to a head again.

Some riggers feel you cannot I&R a rig if the battery will not make it to the next repack.

Others feel that you there is no such restriction.

It becomes more important with the 180 day cycle because you can possibly be tossing a battery that has very nearly 6 months (of 24) life left. With the 120 day rule, you were only talking about 4 months wasted.

It is true that this has not been changed, but exactly what the law is is as unclear as it ever was, so now we are discussing it again.

People have cited various anecdotal evidence for both points of view.

MEL has submitted these questions for FAA answers. Hopefully, whatever the answer is, it will cite the regulations that set the standards so that we can check.

[pringles 0]

The rule is that all components must meet manufacturers guidelines for the full pack cycle. So the batteries must be changed if they expire before the pack cycle does. I don't think it is difficult for people to understand. Its just that some of these issues must have been over looked before the rule was written and released. So now you have people on here getting a chance to proof read and discuss. Something that should have happened before the written release.

one issue that has been brought up was that if a rig was packed in September, 2 months before the rule was written and released now is good for 6 months. The rigger packed it up knowing that the batteries were due in February (after the 120 cycle would be to expire). However now with the rule change the pack job is good till March. So the life of the pack job out lives the batteries.

As was mentioned before if I wanted to pack up a rig today that the batteries were to expire on May 31 I would have to replace them. Now you are loosing almost 6 months of the battery life. The 31st would be like the 176 day of the pack job. You are essentially loosing a quarter of the life of the battery. That kinda sucks when you are spending up to $80 on those batteries.

Matt Davies

[riggerpaul 1]

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The rule is that all components must meet manufacturers guidelines for the full pack cycle.

Can you tell me the FAR that says this? No one else has been able to so far. If you can point at the law, then the issue will be closed.

[howardwhite 2]

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I emailed the FAA to clear this up last week.

Can you share the name/FAA office/title etc. of the FAA person who sent you this?
Local? DC?

HW

[ZigZagMarquis 8]

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And your point? This is what the whole thread has been discussing and apparently the feds can't decide how to interpret.

Was just posting the link as I found it informative and thought others might as well, but agree it and other things surrounding this change aren't as definitive as maybe they should be. [sarcasm] Which I'm sure us yammerin' on about it and takin' the piss out of one another will solve quickly [/sarcasm].

Anyway, does anyone know for sure what the ruling is on rigs currently having been packed under the 120-day rule come 19 Dec? e.g. Do they get a 2-month "bonus" or are they still due for repack in 120 days and its only those rigs re-packed on or after 19 Dec that will then come due in 180 days?

Fortunately, come June 09, it won't matter.

[jojo0815 0]

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Can you share the name/FAA office/title etc. of the FAA person who sent you this?
Local? DC?

HW

it was [email protected] who is listed on the FAA docket for questions.

on the battery issue, if the cypres needs service or batteries before the end of the next cycle, I inform the customer and give him the choice to either do what's necessary now, or if he needs the rig I mark the data card with the component that needs replacement and when.