To the day reserve job question

[riggerpaul 1]

Quote

>If you are using the parachute today, then "yesterday" is "1 day before
>the date of its use".

Agreed. But yesterday may not be _within_ 1 day before the date of its use. The semantic argument someone could make is that a rig packed at 6am on Monday, and used at noon on Tuesday, has not been repacked within 1 day before the date of its use.

There is, however, no question that a rig packed on Monday has been repacked within 1 day before the date of its use if it is jumped on Monday.

When all they tell us to record is a date, yesterday is always "within 1 day before the date of its use".

There is no definition in the FARs of "a day". There is no place that I have found in the FARs where maintenance or service is recorded with a time-of-day, only by a date.

There is no distinction in FAR 105 between 00:00 and 23:59. They only mention knowing the date of the jump.

The FARs contain the notion of "night", but that is defined a the time between " the end of evening civil twilight and the beginning of morning civil twilight...". This has no bearing on how to determine when a service or maintenance was required or performed.

If the jump is made on Monday at 23:59, it is still "Monday", and Sunday is 1 day before that jump. 23:59 might as well be 00:00 as far as the law, as stated, is concerned.

Sunday is 1 day before Monday, no matter when in Monday you are talking about.

Don't make this more complicated than it needs to be.

There is no mention anywhere of recording either the time of the repack or the time of the jump. Anytime yesterday is "within 1 day" of anytime today, because we only have the dates for reference.

Trying to add a time-of-day issue here is just inventing law that doesn't exist.

[Remster 24]

Wow... took a while but the thread got busy! lol

For future reference, Eloy uses a table that the ladies at manifest check, and their table show that for a reserve packed on Nov 26, the day it expires is May 25, but that last day is still jumpable on that repack.

So, to sumarize, that DZ followed the same logic Paul used. And, personally, it was about fitting a Cypress 2 four year check in there, with a few events leading up and inlcuding May long weekend, sending it after that works better for me.

Thanks guys.

Remster

[riggerpaul 1]

Thanks for posting that!

I wonder, do you think people will consider believing my logic now that they know that a big DZ uses the same logic?

Or do you think they'll all start calling Skydive AZ to tell them what a big mistake they are making?

(Okay, I apologize for my sarcasm.)

[popsjumper 2]

Quote

Not agree.
The actual rule says "180 days before the date of its use". By my interpretation, the repack may have been done today or on any of the 180 "yesterdays".

Keyword "within" missing.

Quote

This means a repack is actually good on a total of 181 days.

181 days is outside the 180-day limit.

Quote

Given a repack date of 26 Nov 2008, you have that day and 180 more days to use that parachute before another inspection is required.

No. The day of repack, Nov 26, counts as Day 1.

Quote

25 May 2009 is the last of the "180 more days", so it is legal to jump the rig on that day.

Using your count and the idea that re-pack day is Day 1, May 25 is 1 day outside the 180-day limit.

One step further....since "within" is in there, maybe the 180th day does not qualify because it is ON the 180-day limit and not WITHIN the 180-day limit.

My reality and yours are quite different.
I think we're all Bozos on this bus.
Falcon5232, SCS8170, SCSA353, POPS9398, DS239

[billvon 2,434]

>There is no definition in the FARs of "a day".

You're right. There's an ambiguity there.

>The FARs contain the notion of "night" . . .

You can attempt to parse it however you like, and your defense of your position is a reasonable one. However, there exists an ambiguity there, and thus may be interpreted either way. "Within a day," since "day" is not defined, may or may not mean that a repack within 24.1 and 47.9 hours of use is "within a day."

[riggerpaul 1]

Quote

Quote

Not agree.
The actual rule says "180 days before the date of its use". By my interpretation, the repack may have been done today or on any of the 180 "yesterdays".

Keyword "within" missing.

Quote

This means a repack is actually good on a total of 181 days.

181 days is outside the 180-day limit.

Quote

Given a repack date of 26 Nov 2008, you have that day and 180 more days to use that parachute before another inspection is required.

No. The day of repack, Nov 26, counts as Day 1.

Quote

25 May 2009 is the last of the "180 more days", so it is legal to jump the rig on that day.

Using your count and the idea that re-pack day is Day 1, May 25 is 1 day outside the 180-day limit.

One step further....since "within" is in there, maybe the 180th day does not qualify because it is ON the 180-day limit and not WITHIN the 180-day limit.

The rule does not state anywhere that the repack is good for 180 days. It describes a way to count the days to see if a repack meets the law.

Yes, "within" is used. But "before" is also used. "Within 180 days BEFORE the date of its use" is the exact phrase.

It does not say "Within 180 days INCLUDING the date of its use".

If it said that, I would agree with your notion of the 180 being the max usable days.

But with the word "before", you need to start the count with the day BEFORE the jump.

[riggerpaul 1]

Quote

>There is no definition in the FARs of "a day".

You're right. There's an ambiguity there.

>The FARs contain the notion of "night" . . .

You can attempt to parse it however you like, and your defense of your position is a reasonable one. However, there exists an ambiguity there, and thus may be interpreted either way. "Within a day," since "day" is not defined, may or may not mean that a repack within 24.1 and 47.9 hours of use is "within a day."

I do want to thank you for your consideration of this question, and your willingness to continue the discussion. You force me to find the simplest terms to describe my logic, and simple is just about always better.

You are still trying to talk about hours. There is no mention of hours. Don't try to add the notion of hours to the problem.

In aviation, the limitations on maintenance and service are defined by the calendar, not by the clock. In the absence of further definition, a "day" is a day on the calendar. That's the way that aviation maintenance logs are evaluated.

The law says "within 180 days before the date of its use".

So just ask, "Which are the 180 days before the date of the jump?"

That's the question to ask as the law is written.

We know what a date is. We know which day is the day before any date. Just look on the calendar and you can see which is the day before the jump. No extra definition of "day" is needed. No mention of hours or time-of-day is needed.

Look at a calendar and count the 180 days before the date of the jump.

If you are repacked within those days and your jump, you are good.

Interestingly, there remains a possible ambiguity concerning if you are allowed to jump on the actual day of the repack. One might argue that today is not "within 180 days before today". But the idea of the law is to say that an inspection and repack is done no more than some period before the actual jump, so I think it is not necessary to argue that jumping on the day of the repack is allowed.

[danornan 65]

Interesting post, but for most skydivers, the bottom line is very relevant, but only at the manifest of their local DZ and where they plan to jump.

Until something simple and universally understood is agreed upon, better check to see how YOUR manifest interprets the rule and error on the side of 179 days.

Since the new rule went into effect, I use 179 days as my cutoff. Happy for the change.

Dano

[billvon 2,434]

>You are still trying to talk about hours. There is no mention of hours. Don't try
>to add the notion of hours to the problem.

Well, here on the net, you can insist that we ignore hours. An FAA DPRE, though, may use his common knowledge that a day consists of 24 hours, and in such a case he may not respond well to your insistence that he ignores the 24 hour day.

>Look at a calendar and count the 180 days before the date of the jump. If you
>are repacked within those days and your jump, you are good.

I tend to agree, and that's the standard I use.

> One might argue that today is not "within 180 days before today".

I agree, and I'd base that on the perception that some people have that a rig packed in the early morning was not packed "within a day" of a jump made late at night on the next day. (Or "within 180 days" of the same scenario.)

[pilotdave 0]

Quote

a rig packed in the early morning was not packed "within a day" of a jump made late at night on the next day.

As I said before, repack time isn't logged. Why not assume a repack time of 11:59pm if you're going to worry about minutes instead of dates?

Dave

[riggerpaul 1]

Quote

Well, here on the net, you can insist that we ignore hours. An FAA DPRE, though, may use his common knowledge that a day consists of 24 hours, and in such a case he may not respond well to your insistence that he ignores the 24 hour day.

FAR 105.43, the law that tells us the currency requirement for a reserve repack, doesn't mention the time of the jump.

The law regarding logging the repacks is FAR 65.131. It states:

---

(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.

---

There is no mention of the time of the repack. We are not required to record it.

How is that DPRE going to tell us that the time-of-day matters when FAR 65.131 does not require logging the time of the repack, and FAR 105.143 does not mention the time of the jump?

Sorry, Bill, that DPRE is hallucinating.

The only thing that matters are the dates.

[billvon 2,434]

>Sorry, Bill, that DPRE is hallucinating.

Good luck with that angle.

[riggerpaul 1]

Quote

>Sorry, Bill, that DPRE is hallucinating.

Good luck with that angle.

Is that the best you can do?

I've shown you, and backed it up with law, that time-of-day cannot be a factor.

Are you finally admitting that the time-of-day is irrelevant?

[billvon 2,434]

>Are you finally admitting that the time-of-day is irrelevant?

?? I'm not saying you are wrong. I am pointing out that not all DPRE's see it that way, and may not buy your assertion that you really have 181 days based on a semantic argument concerning how time is never mentioned in the FAR's.

[riggerpaul 1]

Quote

>Are you finally admitting that the time-of-day is irrelevant?

?? I'm not saying you are wrong. I am pointing out that not all DPRE's see it that way, and may not buy your assertion that you really have 181 days based on a semantic argument concerning how time is never mentioned in the FAR's.

I apologize if I jumped on you without cause.

I thought you disagreed with the way I am counting.

I guess you are just playing the devil's advocate.

Anyway, back to the discussion -

So, you are saying you know a DPRE who says you need to consider the time-of-day of the jump and/or the repack?

Please tell us who that is.

I'll be happy to take the issue directly to whoever it is.

[sdctlc 0]

Quote

Thanks guys... I know May 25 is exactly 180 days after Nov 26. I guess its a grey area... I'll ask manifest this weekend, since they are the ones who will be checking it,

If it is a shade of Grey, why not just get it packed a week (few days) early?? You take away all question and with the 180 day pack cycle it is not like your loosing much. It seems much easier to go at it this way then to try and push the envelope.

ON a technical question, don't reserves have to packed at 120 days if they were not packed after the 180 day cycle was implemented??? I could be completely wrong on that but that was my understanding..

Scott C.

"He who Hesitates Shall Inherit the Earth!"

[Remster 24]

Quote

why not just get it packed a week (few days) early??

As I explained in my post, I also need to send my Cypress 2 for its 4 year check. And I have several events leading up to the end of May.

Quote

You take away all question and with the 180 day pack cycle it is not like your loosing much.

I took away all questions by asking the DZ.

Quote

push the envelope

Seriously? Asking this is pushing the envelope????

Quote

ON a technical question, don't reserves have to packed at 120 days if they were not packed after the 180 day cycle was implemented??? I could be completely wrong on that but that was my understanding..

Actually, no. In fact, reserves that were coming out of date after their 120 days could come back into date if they were still withing 180 days when the ruling came into effect,

Remster

[sdctlc 0]

Quote

Quote

why not just get it packed a week (few days) early??

As I explained in my post, I also need to send my Cypress 2 for its 4 year check. And I have several events leading up to the end of May.

Quote

You take away all question and with the 180 day pack cycle it is not like your loosing much.

I took away all questions by asking the DZ.

Quote

push the envelope

Seriously? Asking this is pushing the envelope????

Quote

ON a technical question, don't reserves have to packed at 120 days if they were not packed after the 180 day cycle was implemented??? I could be completely wrong on that but that was my understanding..

Actually, no. In fact, reserves that were coming out of date after their 120 days could come back into date if they were still withing 180 days when the ruling came into effect,

Well then I can understand the cypress issue but the rest my bad I guess for not reading all the way down through the time of day and counting and how to count debates. I still seem to remember when this conversion started that a point of confusion involved an out of date reserve, but one that would still in date based on the new rules, would not magically come back into date but Hell, I have been wrong before and that is what I was basing it on..

As for the rest, do what you want.. Pushing the envelope was taken too harsh so "F" it who cares. I was basing my statement on my understanding of an out of date reserve right on the edge of a boogie and really did not care about the rest as it is usually the type of crap that is posted here to try and explain someone doing something that they want affirmation for. My opinion on that was that the weekend was not really seeming that important to not get it repacked a few days early, no reason to "Push" it but again that might have been pushing it in the verbage.

Oh well

Scott

"He who Hesitates Shall Inherit the Earth!"

[popsjumper 2]

It's really all very simple oflks...

Count the day of the jump as Day 1 and count the calendar days back towards the repack day.

If repack day is 180 or less, go for it.
If repack day is 181 or more, you're out of date.

I don't think anybody could reasonably argue with that.

Or, just go by whatever manifest tells you...they have the last word anyway.

My reality and yours are quite different.
I think we're all Bozos on this bus.
Falcon5232, SCS8170, SCSA353, POPS9398, DS239

[mark 103]

Quote

It's really all very simple folks...

Count the day of the jump as Day 1 and count the calendar days back towards the repack day.

If repack day is 180 or less, go for it.
If repack day is 181 or more, you're out of date.

I don't think anybody could reasonably argue with that.

Or, just go by whatever manifest tells you...they have the last word anyway.

I'm unreasonable, and a bit simple.

Count the day of the jump as Day 0, and count yesterday as Day 1. Any time yesterday is within a day of today. The analogy is the FAA's requirement for an airplane annual. If you'd like to fly your airplane in February 2009, you'd need to check to see if the previous annual was completed in February 2008. The FAA is okay with you flying until the very end of February 2009 even if the annual was completed at the very beginning of February 2008, almost 13 months earlier.

Mark

[riggerpaul 1]

Quote

It's really all very simple oflks...

Count the day of the jump as Day 1 and count the calendar days back towards the repack day.

If repack day is 180 or less, go for it.
If repack day is 181 or more, you're out of date.

I don't think anybody could reasonably argue with that.

Or, just go by whatever manifest tells you...they have the last word anyway.

Your method represents a law that say "within 180 days INCLUDING the date of its use".

The actual law says "within 180 days BEFORE the date of its use".

There is no mention of time-of-day in any of these laws. So you can only say that anytime of the day prior to the jump is "1 day before the date of its use".

Try it this way, there is no time ON the DATE of the jump that is "BEFORE the DATE of its use", is there?

You jump on Sunday. Sunday is the "DATE of its use". Saturday is the first day "BEFORE the DATE of its use". Saturday is day 1 of the count.

Just look at a calendar and find the 180 days BEFORE the DATE of the jump.

That's what's called for by the law as it is written.

[ficus 0]

Quote

It's really all very simple oflks...

Count the day of the jump as Day 1 and count the calendar days back towards the repack day.

If repack day is 180 or less, go for it.
If repack day is 181 or more, you're out of date.

I don't think anybody could reasonably argue with that.

Here's a reasonable argument: I am 29 years old. This is the 30th year of my life.

Ficus

[ChangoLanzao 0]

Quote

Quote

It's really all very simple oflks...

Count the day of the jump as Day 1 and count the calendar days back towards the repack day.

If repack day is 180 or less, go for it.
If repack day is 181 or more, you're out of date.

I don't think anybody could reasonably argue with that.

Here's a reasonable argument: I am 29 years old. This is the 30th year of my life.

Ficus

Congratulations! You're over the hill

[popsjumper 2]

OK...it just seems to me that the day of the jump and the repack day are days that are counted...neither one of which is Day 0. There's no such thing as Day 0. If you don't count jump day OR re-pack day, you get 181 days of legality...clearly not within the 180-day limit.

Whoa! What if we counted neither jump day NOR repack day? 182 days of legality??? NOW we're talkin!

It seems that you are saying:
Day 181: Jump Sunday.
Day 180: Saturday
Day 179: Friday
.
.
.
Day 0: Repack day.

What I'm thinking is:
Day 180: Jump Sunday.
Day 179: Saturday
Day 178: Friday
.
.
.
Day 1: Repack day

Where within 180 days includes the entire day up to the beginning of Day 181. That's using end-of-day 180. Your interpretation says use beginning-of-day 180 which puts Day 180 (jump day) out of bounds.

Not arguing, just clarifying. But it is an interesting excercise to evaluate different interpretations.

For me personally it's a moot point because I'd never let it go that far anyway. Well, except that one time when I went brain-dead and got surprised on a data card check.

I had to put that in there because my rigger sometimes reads these threads and he'd bust my balls if I didn't 'fess up.

My reality and yours are quite different.
I think we're all Bozos on this bus.
Falcon5232, SCS8170, SCSA353, POPS9398, DS239

[riggerpaul 1]

You seem to be stuck on the notion that the "180" in the law means we have only 180 days.

You are not the only one stuck on that idea by any means.

But what the law says is to count the 180 days before the date of use, and if it is packed not earlier than that 180th counted day, it is legal to use.

The exact words are "The reserve parachute must have been packed by a certificated parachute rigger within 180 days before the date of its use,..."

Which days does that tell us to count? Count the days before the date of its use.

We do count the repack day. We don't count the jump day, because it is not "before the date of the jump".

That gives a total of 181 possible legal jump days. Practically, the rig is not usually returned on the day of the repack, so you actually get fewer than the full 181.

Some have theorized that a "day" in this context is 24 hours, and that the whole legal interval is 180 days times 24 hours. This cannot be the case since there is no requirement to log the time of the repack. Additionally, the law (quoted above) makes no mention of the time of the jump. It only mentions the date of the jump.

So the only thing to do is to count calendar days, and the days that you count are all "before the date of its use".