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JerryBaumchen

Paper Seals

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Hi there,

There is a small but growing effort to get Paper Seals accepted in this country, the USA.

One local Master Rigger is using them exclusively. He was recently in DeLand for some POPS jumps and was showing them to folks there. He said that everyone liked the idea; and he was allowed to jump his two rigs with the paper seals on them.

Allen Silver, the head of the PIA Rigging Committee, has had some contact with the FAA on getting some type of interpretation to use paper seals. Some people feel that he should not contact the FAA on this ( just start using them ) and others think that getting the 'OK' from the feds is the better way to go. For those who might want to contact Allen on this, his email is: allen (at) silverparachutes (dot) com

Right now, I do not read anything in any FAA document that defines what a seal must consist of. Yes, I know that a rigger must have a seal press but I do not see where it specifically states that he must actually use it.

For me ( and I know that this is only my thinking ), it is more of what is it that a seal must be for rather than specifics on any procedure/item that is used for sealing a reserve.

Here are some photos of a paper seal that I have been working on. I make these on a label printer that is connected to my computer. All of the info is in a file that I merely open so I can put the Repack Due NLT in prior to printing.

Photo #1 shows a rig with the red rigger's thread installed without any seal.

Photo #2 shows the same rig with one of my paper seals installed.

Photo #3 shows my paper seal as it comes out of my label printer.

Photo #4 is a paper seal made by the local Master Rigger as installed on one of his rigs. You will notice that his paper seal only goes around the knot on one leg of the red thread; I do think this is the better & simpler way to install a paper seal.

It should be noted that the 'Repack Due NLT' date is not binding; the governing document is the Packing Data Card. This 'Repack Due NLT' date is a way to keep the user informed of when he needs to get his reserve repacked; everyone does check their reserve pin before the start of jumping each do, don't you?

Now that you've had a looksee, what comments would people like to offer?

And if anyone has any questions, just post them here or send them to me via email.

Thanks,

JerryBaumchen

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Is this all the FAA says on the matter?:

Quote

§65.133 Seal.
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



For a first stab at this:

Under US rules,
a) you still need to have a seal press
b) you still have to seal the reserve (...the standard seal thread is probably a good idea)
(There is the argument that you could seal it and rip it off right afterwards and be legal.)
c) sealing probably involves one's seal press (due to "with his seal")

So it looks like one could use seal thread, and use one's seal press on a paper adhesive label attached to the seal thread. If the manufacturer allows it.

My regular press, despite having inset (not raised) characters on it, will create something of an impression on paper, maybe enough to be practical. But the jaws don't close fully so one has to either add something behind a die to close the gap, or use a temporary spacer to be squished along with the paper.

As for "in accordance with the manufacturer's recommendation", the PIA might best get manufacturers to agree on some alternative new standard.

For the short term, one can get into the business of parsing exactly what is in each company's manual -- some don't even mention the sealing, and many say "seal the reserve" but don't mention lead seals.

In such cases, things seem good to go -- there's nothing stopping an FAA rigger, right now, from using a paper seal on a variety of popular rigs!

Naturally it might concern jumpers if there's no high level statement about it from the USPA or PIA.

Or did I miss something?

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I have always had the impression that one reason for the current lead seal was that it is somewhat resistant to "forgery". With the current lead seals it takes a fair pit of effort to fake a seal. The paper seals would be MUCH easier to fake.
The choices we make have consequences, for us & for others!

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The FAA's Parachute Rigger Senior/Master-Certification Guide (AC 65-5B) is part of the same regulatory section (14 CFR §65) as §65.133 cited above (and thus they are intended to apply in conjunction with each other). The Guide does specifically refer to lead seals.

PDF version:
http://rgl.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRCULAR.NSF/0/9a2a098126ceb0ec862569dc00722032/$FILE/ac65-5b.pdf

HTML version:
http://74.125.93.104/search?q=cache:Nhp8UcnigOIJ:rgl.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRCULAR.NSF/0/9a2a098126ceb0ec862569dc00722032/%24FILE/ac65-5b.pdf+%22AC+65-5B%22+cfr+lead&cd=2&hl=en&ct=clnk&gl=us

Based on this, I would predict that the FAA would probably rule that the seals currently must be made of lead, and that, if the issue were to be litigated, a court would probably sustain that ruling.

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Only as hard as ordering a die from Para-gear.


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I have always had the impression that one reason for the current lead seal was that it is somewhat resistant to "forgery". With the current lead seals it takes a fair pit of effort to fake a seal. The paper seals would be MUCH easier to fake.


He who hesitates shall inherit the earth.

Deadwood
Skydive New Mexico Motorcycle Club, Touring Division

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what about using some sort of embossing type seal? it would be harder for someone to just print up a fake seal and put it on their reserve. i think the idea of using a lead seal and sealpress accomplishes this,but i like the paper seal idea better.just dont care for the idea that ANYONE witha computer and printer could print up a fake seal and stick it on their rig.has to be something that the average jumper wouldnt have ready access to in order to make it counterfeit resistant

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Only as hard as ordering a die from Para-gear.


Quote

I have always had the impression that one reason for the current lead seal was that it is somewhat resistant to "forgery". With the current lead seals it takes a fair pit of effort to fake a seal. The paper seals would be MUCH easier to fake.



True, but look at the relative effort:

Faking a lead seal:
-- Buy seals 100 for ~$10
-- Buy seal press and seal ~$63
Relatively few places to buy the above.

Faking a paper seal:
-- A box of labels ~$10 and available almost everywhere. Heck, if you are like me you already have labels of various sizes sitting on the shelf... my marginal cost to fake a seal would be zero.
The choices we make have consequences, for us & for others!

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Only as hard as ordering a die from Para-gear.


Quote

When I got my ticket I ordered my seal press dies from Para-gear but I didn't like how they looked so I made my own. I work at a machine shop and it probably took me longer to order them than it took to make them.



Blue Skies

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Now that you've had a looksee, what comments would people like to offer?



That paper seal would not be tamper-proof.
It would be very easy for someone to open the reserve and then reseal it.
It could also be pencil packed easier.

Folding the label in half and exactly matching up the contact area is subject to the user's ability. Any areas that did not overlap could potentially leave a gummy residue on the rig and attract dirt to the label itself.

The seal itself would not last long in the hot desert. The glue on those types of labels dries out very quickly. It turns into a course, flaky form and the label would fall off.

The ink (assuming it's from a inkjet type printer) will run with exposure to liquids, humidity, swoop pond landing, sweat from hands handling it.

The worst part about that label would be when the RC was pulled through the housing. The label might tear and leave pieces of it anywhere inside the housing. That would be hard to inspect and clean. It could even prevent the ripcord from clearing the housing.

.
.
Make It Happen
Parachute History
DiveMaker

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The seal itself would not last long in the hot desert. The glue on those types of labels dries out very quickly. It turns into a course, flaky form and the label would fall off.

The ink (assuming it's from a inkjet type printer) will run with exposure to liquids, humidity, swoop pond landing, sweat from hands handling it.

....................................................................

Sort of like the glue on sticky ripstop nylon patches.
The challenge is to chose a glue that dries out in 170 days.
Built in obselescence might be a good idea.

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Jerry,

Some discussion now that I'm back at work.:P

What is your goal? I just not sure what problem you want to solve.
To get away from lead..
because of environmental reasons?
because of economic reasons?
because of functional (jamming) reasons?
Lead isn't the issue but...
want more information on the seal?
want the seal legible?
Something else?


If it's getting away from lead I've been playing with plastic seals that function like the lead seal and take the imprint from the press. Some sample were sent to be from Europe (I can't remember by who) and supposedly I ordered some but not sure the company is really functioning. I've heard that the aluminum in the plastic seals cuts the thread but I haven't tried it enough yet to know.

Lead seals often aren't legible because they are barely big enough to get the 3 letters to fit. I bought some 1/2" lead seals and the code that lets the seal symbol be read easily.

If it's more information, I'm not sure thats the place for it. Some riggers put due date on card or on label on handle (not possible on soft handles.) I don't have an issue with all the info you put on your paper label but not sure why?

I have some of the same concerns that Jan does. Durability might be an issue. Paper, adhesive and ink. Laser printer should be better than inkjet for ink but I don't think they are real common at home. There are crappy labels and some better labels. And the lead brakes off and doesn't go into the housing for the most part. Paper will. Not sure that's much of an issue but is different.

Jerry, I haven't played with the labels you sent me yet. (Two kids under 3 makes it hard to get to anything:S But they seemed to be of somewhat higher quality. I think you also said you had a dedicated label printer. I would guess most of us don't. Also yours struck me as pretty big. The might actually have trouble hiding under some pin protectors. I thinking more of some pilot rigs. It seems on the Softies I have to consider where to put the lead seal to protect it.

Also, tough to replace yours in the field since they are rig specific. The other smaller version you showed can be preprinted and kept in the rigger kit.

My biggest concern is probably acceptance. Right now, even if we believe the FAR's allow it it doesn't matter. Its the individual inspector or DZO that makes the call. I'd hate to have a warbird pilot at an airshow grounded because the inspector that ramp checked them doesn't like the seal. Same thing with a jumper at a DZ. Even IF the FAA blessed them, I can imagine having to prove it to a lot of inspectors.

I'd like to get away from the lead seals just because now I have to keep the kids from finding them.:S And I'd use paper seals if I knew they wouldn't be turned away and were durable enough.

I found these tyvek diecut laser printable labels avaiable in any custom size.
http://www.rippedsheets.com/laser/102014TyvekLaserPrintableTearproofWaterproofLabel.html

That might be better than paper but I don't have a laser printer and again it wouldn't be one at a time.

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

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I've seen them used by a US Rigger. He had an embossing seal with his symbol. His seal was smaller then the fullsize label, but larger then the small one. He also signed it and put "matchmarks" on it to prevent seal/reseal. The label had a place for due date and date packed.

I really doubt the adhesive would dry out. The one I saw (broke) was 13 months old and mostly kept in the airplane, in the airplane hanger in West Texas. The only time it left that hanger was to fly a show and return a few days later. No sign of drying out.

I like them, and have considered using them. I haven't gotten around to getting any printed up yet.

If I use them, I would have the labels printed on tyvek which would prevent forgery.

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Ease of use
reduce handeling of lead
easier to prevent pencil-packing
clarity of due dates for my customers
clarity of due dates/information for manifest(s)

In other words, no good reason. I don't see an issue with the lead seal, but I don't see any compelling arguement to keep it. I've got about 50 seals left, so I won't be changing that soon.

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'Ease of use'

I'm pretty fast with my seal and I've aready filled out the packing data card, now I had have to fill out something else.

'reduce handling of lead'

yep, and less lead for my kids to eat

'easier to prevent pencil-packing'

I already use a unique stamp with my seal on the card. But I guess a due date on the seal might be good.

'clarity of due dates for my customers'

Hell, we can't even decide how to COUNT 120/180 days on here.;) I know when it's late, but maybe not when it's close.:S (and yes I have my opinion)

clarity of due dates/information for manifest(s)

yeah, maybe. But about half the non home DZ's I've been to only wanted to see the card, not the rig/seal.

Of course there is the Paragear argument that less is more. The story Lowell (Blue skies Lowell) told about Paragear being sued because a BLANK packing data card imprinted with Paragear on it that they used to sell was in a rig. They didn't sell the rig, pack the rig, or have anything else to do with it other than sell someone a 2cent piece of paper that had Paragear's name imprinted on it. $10,000 later dismissed from the suit. Already have the seal, certificate number and illegible name ;) but why give them more.

Just arguing for arguing's sake.B| I might use preprinted tyvek with due date space but because I wouldn't need a printer at hand. Probably not go to Jerry's full disclosure custom for every rig printed version.:P I'm too lazy for that.:)

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

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