Major/Minor? (Was TI Injury @ Orange)

[NovaTTT 1]

Re RiggerPaul's comments:

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The whole notion of major and minor repairs as they are currently defined is seriously lacking.

Don't we know it. The PIA Rigging Committee should draft something in clear language that the FAA would be willing to consider. Does anyone know if it's in the works or has been tried before?

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Replacing velcro on a riser is commonly though of as a minor repair....One careless moment with a knife is all it takes. So, is it really minor?

I think this doesn't apply, because the reg is "if improperly done", which I take to mean the task is accomplished but is done so improperly or inadequately. What you are describing is simply a mistake, a screw-up along the way, which adds work and/or rigger cost to the repair.

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We must currently rely on "common sense" to determine where the practical limits lay. But "common sense" limits vary greatly from person to person.

Agreed.

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If we really want to be able to apply legal weight to the notion of who can do what, things really should be far more clearly defined than they are now. Simply talking about airworthiness is not sufficient.

Without that clarity, it really all comes down to opinions. What one Mark thinks is major, another Mark thinks is minor. Neither is clearly right; neither is clearly wrong. And we are left in a muddle.

Again, perhaps the PIA Rigging Committee should be looking at this. I specify the PIARC because were it to be left to the manufacturers, we would not have the desired uniformity of understanding.

"Even in a world where perfection is unattainable, there's still a difference between excellence and mediocrity." Gary73

[riggerrob 558]

May I suggest that a minor repair should only be done on simple (301 straight stitch or 304 single-throw zig-zag) sewing machines pulling E thread).

Minor repairs should not require re-closing a seam (eg. re-sewing a rib to a top skin).

Replacing a broken stitch is a minor repair, but changing a stitch pattern is a major repair. Replacing structural harness components (2500 pound buckles) should count as a major repair.

Major repairs require complex sewing machines like Class 7 (5 cord) or bar-tackers (E thread).

A Senior Rigger should be required to sew dozens of minor repairs (simple canopy patches in the middle of panels, a long way from top or bottom seams) before attempting major repairs (eg including a canopy seam).
The first few major repairs should be done under the supervision of a Master Rigger.
Any repairs in the gray area (between minor and major) might be sewn by an FAA Senior Rigger, but should be inspected by a Master Rigger before returning to service. This gives Senior riggers an opportunity to learn (under supervision) and an opportunity for Master Riggers to teach the finer points.

[airtwardo 6]

They use to say, if you can jump it again and survive...it was a 'minor' repair needed.

~ If you choke a Smurf, what color does it turn? ~

[riggerpaul 1]

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Re RiggerPaul's comments:

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The whole notion of major and minor repairs as they are currently defined is seriously lacking.

Don't we know it. The PIA Rigging Committee should draft something in clear language that the FAA would be willing to consider. Does anyone know if it's in the works or has been tried before?

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Replacing velcro on a riser is commonly though of as a minor repair....One careless moment with a knife is all it takes. So, is it really minor?

I think this doesn't apply, because the reg is "if improperly done", which I take to mean the task is accomplished but is done so improperly or inadequately. What you are describing is simply a mistake, a screw-up along the way, which adds work and/or rigger cost to the repair.

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We must currently rely on "common sense" to determine where the practical limits lay. But "common sense" limits vary greatly from person to person.

Agreed.

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If we really want to be able to apply legal weight to the notion of who can do what, things really should be far more clearly defined than they are now. Simply talking about airworthiness is not sufficient.

Without that clarity, it really all comes down to opinions. What one Mark thinks is major, another Mark thinks is minor. Neither is clearly right; neither is clearly wrong. And we are left in a muddle.

Again, perhaps the PIA Rigging Committee should be looking at this. I specify the PIARC because were it to be left to the manufacturers, we would not have the desired uniformity of understanding.

You don't like the velcro example, and say that mistakes are not what the regulations are trying to address.

So, what are the regulations trying to address?

Do you think that there are a whole lot of senior riggers out there who are just making stuff up? If that's what you think, I don't think we can address the problem with regulation. If people are willing to do something that they know full well they don't know how to do, you aren't going to stop that with regulation. Regulations will mostly keep the people who are already conscientious, and not willing to do things that they cannot do, from doing more things. They are not going to protect the jumping public from cowboy riggers who will always do whatever they please.

Anyway, what sort of error is not just a mistake at some level. Please give an example. Because a conscientious rigger will research his work if he has not done it before. And if the research doesn't not result in a clear understanding of the task at hand, he will not proceed.

Using the example of replacing the locking loop on a riser, do you think that with those machines and those instructions, you could not accomplish that task? Do you think that you could not tell if your work was acceptable?

But, according to riggerrob's suggested limits, it should not be done because it uses a 308 zigzag and a Class 7 machine.

Don't get me wrong, I don't think Rob's suggestions are off the wall or anything, but trying to write rules about this is a slippery slope.

I think this repair is pretty straightforward, and the instructions are pretty clear. Just because the machines involved are outside the normal home machines, that doesn't clearly mean that it is too complicated for a senior rigger. And, after all, Sandy Reid, an accomplished expert in his own right, says it is acceptable for a senior rigger to do this work.

Maybe the only practical approach is to establish a set of instructing that describe all the work that a senior rigger can do. Maybe the whole thing hinges on how good the instructions are, as opposed to drawing a line in the sand that a senior must not cross.

Over time, the library of accepted instructions would grow, and existing instructions would be updated. Using this sort of library, a senior could be fairly certain that he was doing things the right way.

Maybe that would be a good task for the PIA rigging committee? Establishing the library of instructions for the tasks we need to accomplish.

Sure, it is different from the way things are done now, but it also has a certain elegance. It will automatically help seniors gain experience they need on the journey to being a master, and it will help keep them out of the fuzzy fringes of new work and techniques that are being developed, if only because they don't yet have appropriate reference materials from which to work.

[JerryBaumchen 1,047]

Hi Paul,

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Using the example of replacing the locking loop on a riser, do you think that with those machines and those instructions, you could not accomplish that task? Do you think that you could not tell if your work was acceptable?

But, according to riggerrob's suggested limits, it should not be done because it uses a 308 zigzag and a Class 7 machine.

Let me throw something wildly different at you. At one time I was actively engaged in mfg sport rigs. I had a complete set of the instructions on how to make 3-ring risers. I did not agree with them completely ( and I was not the first person to 'change' the method of mfg them ). I made a lot of sets of 3-ring risers by sewing the white loop in place using 'E' thread and a simple straight stitch. I then, blasphemy of blasphemies, actually sewd ( is that a word? ) the confluence on with 'E' thread. In all of the years since, I have never had a riser failure.

Heck, Rigging Innovations/Sandy Reid built 3-ring risers without a confluence wrap.

There are more ways than one to skin a cat.

However, I do believe that a rigger, Senior or Master, should follow the original mfg procedures. If they don't know them, then they should contact the mfr or not do the work.

Again, just my thoughts,

JerryBaumchen

PS) In my 45 yrs of being a parachute rigger I have turned down a lot of work because I was unsure of how to do it or I did not possess the proper equipment to do it correctly.

[KevinMcGuire 0]

I think this repair is pretty straightforward, and the instructions are pretty clear. Just because the machines involved are outside the normal home machines, that doesn't clearly mean that it is too complicated for a senior rigger. And, after all, Sandy Reid, an accomplished expert in his own right, says it is acceptable for a senior rigger to do this work.
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Beware when taking Sandy Reid's opinion as fact or word from god. Particularly when it comes to what repairs should and should not be performed by a senior rigger.
In Sandy's 2005 rigger study guide he expressly says that a senior rigger can perform a line replacement on a canopy. This was never the case before he wrote his study guide. He just decided that it should be so.

Let us not forget that such a repair, if done improperly could very easily have a negative effect on the structural integrity, weights and balance and flight/opening Characteristics of a canopy. To me that sounds like a major repair

Is replacing a line on a canopy an easy repair? You bet providing the person doing the job has enough experience. Should a repair of such importance as a line replacement be performed by someone with just enough knowledge to pass the written and practical senior riggers test? Given how little a person needs to know in order to pass, I think not.

Sandy's opinion is only that. His opinion, and I doubt that would do you much good in front lawyer worth his salt and a jury.

[mark 102]

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In Sandy's 2005 rigger study guide he expressly says that a senior rigger can perform a line replacement on a canopy. This was never the case before he wrote his study guide. He just decided that it should be so.

Sigh.

This stuff is not rocket science, and is easier for a rigging student to learn than how to make a decent basic patch, given a reasonably competent instructor.

Poynter expressly says that a senior rigger can perform a line replacement on non-certiificated (main) canopies, both round and ram-air.

If you're not using The Parachute Rigger Handbook or Poynter's, what are you using to train your rigging students?

Mark

[masterrigger1 2]

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This stuff is not rocket science, and is easier for a rigging student to learn than how to make a decent basic patch, given a reasonably competent instructor.

Absolutely!
But the problem is that are two ratings; Master and Senior, which require different testing standards for each to achieve his or her certificate.

Then that certificate holder has to work within those certificate limitations unless under the direct supervision of a master rigger.

What some individuals do not get is the fact that the Senior rigger certificate is just a certified reserve packer and sometimes very minor repairman. That was all that it was meant to be when it was institutied.

But from the lack of oversight, privilages have grown in certain peoples eyes and minds.

The Master rigger O&P is not hard and the only thing keeping the Senior rigger that should have a Master's certificate is the mere scheduling of a O&P with a DPRE.

It's really that simple!

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Poynter expressly says that a senior rigger can perform a line replacement on non-certiificated (main) canopies, both round and ram-air.

You mean the "other" Sandy Reid book, Volume II?
Volume II has a lot of Sandy's influence in it.
Not to mention his numerous pictures of himself........

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If you're not using The Parachute Rigger Handbook or Poynter's, what are you using to train your rigging students?

Like I told AFS-630, I WILL NOT use the PRH for any of my students ..period.
It is a single point of view publication with mostly opinion in it.

As far as what I use. I use widely accepted and published repair practices, along with the regulations.


AFS-630 is looking for a another contractor to write a new reference manual to replace the PRH. They also stated that this one will be handled differently in it's making like having multiple reviews from various people.

Hopefully, we all can have input into it's resources.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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Poynter expressly says that a senior rigger can perform a line replacement on non-certiificated (main) canopies, both round and ram-air.

You mean the "other" Sandy Reid book, Volume II?

No, I was referring to Poynter's books.

Poynter Volume 1 says a senior rigger can perform a line replacement on non-certificated (main) canopies. The procedures are for round canopies, and include link-to-link replacement on continuous line canopies. That's a non-trivial task, and in my mind asks more of a senior rigger than line replacement on a ram-air canopy.

Poynter Volume 2 contains acknowledgments of quite a few people who helped with the book, but in the end Dan Poynter takes responsibility for its contents, no one else. Volume 2 contains instructions on line replacement on ram-air canopies, which allow senior riggers to work on mains, but require masters to work on reserves.

In both volumes, there are different standards for mains and reserves. For example, in both volumes, repair limits are frequently more generous for mains, and in both volumes, the required certificate for any work on a main is frequently just a senior. And that's the way it's been for nearly 40 years.

Mark

[masterrigger1 2]

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In both volumes, there are different standards for mains and reserves. For example, in both volumes, repair limits are frequently more generous for mains, and in both volumes, the required certificate for any work on a main is frequently just a senior. And that's the way it's been for nearly 40 years.

The FAA does do not view it that way, maybe Poynter does but we do not receive our certificates from him.

There cannot be two different standards for airworthiness for the same exact repair.It is either airworthy or not.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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In both volumes, there are different standards for mains and reserves. For example, in both volumes, repair limits are frequently more generous for mains, and in both volumes, the required certificate for any work on a main is frequently just a senior. And that's the way it's been for nearly 40 years.

The FAA does do not view it that way, maybe Poynter does but we do not receive our certificates from him.

There cannot be two different standards for airworthiness for the same exact repair.It is either airworthy or not.

MEL

Perhaps the FAA is not as monolithic as we think. They cite Poynter as a source in the Practical Test Standards, after all.

In other news, which questions exactly did AFS-630 agree to eliminate or change?

Mark

[masterrigger1 2]

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Perhaps the FAA is not as monolithic as we think. They cite Poynter as a source in the Practical Test Standards, after all.

They had no other publication to cite that I know of.

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In other news, which questions exactly did AFS-630 agree to eliminate or change?

They have removed the questions regarding plumb line, etc....
They also have repaired some of the "trivia" questions thank goodness.

Now maybe the rigger candidates that are very rigger savy will be able to pass the test.


BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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They have removed the questions regarding plumb line, etc....
They also have repaired some of the "trivia" questions thank goodness.

Now maybe the rigger candidates that are very rigger savvy will be able to pass the test.

BS,
MEL

That is great news!

There were also some off-the-wall questions about stuff like
-- what happens to stall speed when sink rate increases
-- what happens to glide ratio when weight increases

And some trivia questions about stuff like T-beam construction and load-bearing ribs being sewn onto the top surface and into the bottom surface of span-constructed canopies.

Are those gone too?

Do you have a list of the questions they've agreed to change or eliminate?

Thanks,
Mark

[SpacemanSpiff 0]

All personal opinion aside, I’m struggling to see how a Senior Rigger is prohibited from performing a line replacement on a main canopy. This is not to say that I personally believe that they can or should be able to. I think the point is, though, that I don’t see a clear reason as to why they can not legally perform a main reline. No disrespect, but I also do not think that DPRE or Master Rigger opinions can validate one side of the argument or the other. It seems that, just like everyone else, DPREs and MRs have their own personal thoughts on the matter. And, as we can see, some of these opinions can be on opposite ends of the spectrum.

I think the prudent argument should be one that examines the published FAA rules and guidance in order to explicitly make a determination one way or another. From what I have read over the past few years on this topic, these seem to be the valid arguments which show that a Senior Rigger can in fact reline a main canopy:


1. 14CFR 65.111b allows main parachutes to be packed, maintained OR altered by 4 types of individuals; two of which are either a person who possesses the appropriate current certificate issued under this subpart OR by the person making the next parachute jump with that parachute in accordance with 105.43(a).

2. Advisory Circular AC105-2C (Section 8.a.) states that specific approval is not needed for altering a main parachute

3. Confirmation from the Denver FSDO (FAA) explaining that either a Senior or Master Rigger, someone under the supervision of a Senior or Master Rigger, the person making the next jump on the canopy, or the parachutist in command making the next jump can legally pack, maintain, or alter a main canopy or main container of a 2 canopy system. http://www.dropzone.com/cgi-bin/forum/gforum.cgi?post=784294;#784294

4. The FAA’s Parachute Rigger Handbook (document FAA-H-8083-17) in Section 7.1.9, “Square Canopy – Main Line Replacement,” specifically outlines that an FAA Senior or Master Rigger are authorized to perform this repair procedure.

5. Poynter’s volume 1 & 2, as stated in the posts above. (While these are not an FAA published manual, they have been used as industry standard in the past. Therefore, I’ll leave it to the reader to judge the applicability of this with regards to the argument.)


If someone would take the time to summarize the valid arguments against allowing a Senior Rigger to perform a Main Reline I think many of us would appreciate it. In preparing a response, please avoid personal opinion, indications that the above facts are incorrect and that the FAA is taking action to correct them, or that certain people in the industry are doing one thing or another.


thanks
nick

[riggerrob 558]

"...
3. ... or the parachutist in command making the next jump can ... alter a main canopy or main container of a 2 canopy system...."

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

Just ask any tandem manufacturer what they think of Tandem Instructors (who have never held rigger's certificates) "altering" main containers .... their response will be a loud and angry NO!

Remember that FARS always loop back to maintaining parachutes "in accordance with manufacturers' instructions."

For decades, the FAA has tried to distance themselves from the whole concept of who can repair, alter, etc. MAIN CANOPIES. Unfortunately, the FAA allows lawyers to write FARS, which makes them incomprehensible to mere mortals (read riggers.)
Sometimes FAA lawyers mangle documents so badly that the original authors no longer recognize them: re. This time last year, PIA demanded that the FAA retract TSO C23E because FAA lawyers changed it beyond recognition.

[riggerpaul 1]

The problem, as I understand it, is that 65.125.a.1 does not specifically exclude main parachutes.

This leads to interesting interpretation that, according to 65.111.b, certain non-certified persons might legally do major work on a main, while a senior rigger might not.

Some feel that 65.111.b trumps 65.125.a.1, while others feel that it is the other way around.

This comes down to the question: in the face of conflicting regulations, do we adopt a more conservative, restrictive interpretation, or a more liberal, less restrictive interpretation?

(I am no lawyer, but it has always been my understanding that when one law apparently allows something that another law apparently prohibits, the law that allows trumps the one that prohibits.)

[masterrigger1 2]

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1. 14CFR 65.111b allows main parachutes to be packed, maintained OR altered by 4 types of individuals; two of which are either a person who possesses the appropriate current certificate issued under this subpart OR by the person making the next parachute jump with that parachute in accordance with 105.43(a).

The word "alter" was included in the paragraph so that the instructor could "alter" the parachute packing to make the openings more comfortable if needed.

A lawyer put that in there.

It has been addressed and on Feb 26, 2010, I was told it now has been corrected to reflect it's true meaning.
That meaning is not to allow anyone other than a Master rigger to accomplish alterations on mains.


2. Advisory Circular AC105-2C (Section 8.a.) states that specific approval is not needed for altering a main parachute

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If you read through it all, it means that you do not need approval from either the manufacturer or the FAA if it is non-certificated (main).

You do need specific approval from the manufacturer or the FAA for a certified componet.

In both cases, the repairman has to have a Master's certificate.

3. Confirmation from the Denver FSDO (FAA) explaining that either a Senior or Master Rigger, someone under the supervision of a Senior or Master Rigger, the person making the next jump on the canopy, or the parachutist in command making the next jump can legally pack, maintain, or alter a main canopy or main container of a 2 canopy system. http://www.dropzone.com/...?post=784294;#784294

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First, It was never handled as a legal interp.
The inspector that was quoted, retired shortly afterward.
I talked to him also before he retired and basically he had no clue as to want the regs were even though he was a token rigger.

4. The FAA’s Parachute Rigger Handbook (document FAA-H-8083-17) in Section 7.1.9, “Square Canopy – Main Line Replacement,” specifically outlines that an FAA Senior or Master Rigger are authorized to perform this repair procedure.
***

Just another error/opinion for that document.

There are two types of repair, Minor and Major.

Not major and minor for TSO'd equipment and the same for non-TSO'd equipment.
That would make four types.

Master riggers are the only ones able to do major repairs.


AC-105-2C states that line repair is a major repair and Master rigger required.

So there you have it.


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

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1. 14CFR 65.111b allows main parachutes to be packed, maintained OR altered by 4 types of individuals; two of which are either a person who possesses the appropriate current certificate issued under this subpart OR by the person making the next parachute jump with that parachute in accordance with 105.43(a).

The word "alter" was included in the paragraph so that the instructor could "alter" the parachute packing to make the openings more comfortable if needed.

A lawyer put that in there.

It has been addressed and on Feb 26, 2010, I was told it now has been corrected to reflect it's true meaning.
That meaning is not to allow anyone other than a Master rigger to accomplish alterations on mains.

First off, the online FARs have not changed yet. Maybe they will change soon, but they have not changed yet. Maybe it is too soon to expect to actually see the change yet.

Were you also told that the word "maintain" will be removed?

Because, if it is not, our quandary remains much the same.

[SpacemanSpiff 0]

Thanks for the replies and summary of key points. I think it is good to have the explanation from both sides outlined in the debate/thread so that people can make an educated decision on the issue.

There is no doubt that there seems to be holes in the system. But I think, at the end of the day, the FAA does a pretty good job of trying to ensure safety. And let's be honest, this is probably pretty low priority for them. It's not like people are falling out of the sky because of this. Ok, perhaps they are. But I'd bet that the FAA would initiate a change to the CFRs if people were routinely getting hurt. I haven't checked the historical incident reports, but I'd bet that very few people have been injured because of a sloppily relined main canopy.

Some day the FAA may rewrite the 14CRFs to fix all of this. (By the way, I did check the future effective CFRs and did not see an upcoming change to Part 65. Also, one would think that a change to the CFRs would warrant a public comment period. But I'm no expert on regulation changes). Until then I guess we'll all have to use our ticket as a license to learn and continue to watch the debate.

nick

[masterrigger1 2]

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Were you also told that the word "maintain" will be removed?

AFS-100 and AFS-350 were both in the conference and conversation.
We were working on another agenda and this just came up in the middle of it all.

Basically, it has been defined in its meaning as they both had stated.

I too, am looking for the written version to come out.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[timmyfitz 0]

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Master riggers are the only ones able to do major repairs.


AC-105-2C states that line repair is a major repair and Master rigger required.

So there you have it.

AC's are not regulatory.

[riggerpaul 1]

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I too, am looking for the written version to come out.

MEL

The online 65.111.b still has the words "maintain" and "alter".

But, I just noticed that the page also carries the notation that it is current as of 12 March 2010.

Don't quite know what to make of that.

Maybe we must wait a little longer for things to percolate.

I'll keep monitoring. I'll certainly post if/when anything changes.

[SpacemanSpiff 0]

You can also check the Future Effective CFRs on the FAA's site. On this page you'll see the category on the left side pane. From there, expand the link to search "By Part".

At this time I don't see anything there under Part 65.

Of course, for a change to the regulations to take place, the FAA would need to go through much the same process as was done for the 180 day repack rule. They would need to get it published in the Federal Register for it to go out for public comment. From there, they would have to then disposition each comment before a new rule could be put out.


nick

[masterrigger1 2]

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AC's are not regulatory.

Nope, but it is considered guidance!

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[timmyfitz 0]

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AC's are not regulatory.

Nope, but it is considered guidance!

MEL

So there you have it.