Major/Minor? (Was TI Injury @ Orange)

[masterrigger1 2]

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So there you have it.

ehh..nope I already had it.

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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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

Not necessarily. When the regulations were changed in 2001, mostly to include tandem jumps previously conducted under an exemption, there were a number of unintended changes. For example, before 2001, if you wanted to make an intentional jump, you had to have a main, certified reserve, and certified harness/container. After 2001, if you have a single-harness dual-parachute (skydiving) system, it has to have a main, certified reserved, and certified harness/container -- but the regulation is silent on the requirements if you want to jump a single-harness single-parachute (BASE) system, and therefor allows jumping such a system. That's the literal reading of the regulation, even though the FAA never intended legalizing jumps using BASE equipment.

The rewrite allowing the next person to jump the system to alter it is another such change. Before 2001, the next person to jump the equipment was permitted to pack the main, but a rigger was required to pack, maintain, or alter the rest of the parachute system.

Because these changes were not contemplated in the original Notice of Proposed Rulemaking (NPRM) and were not addressed in the comments and responses, there can be an administrative correction. Because the administrative correction would be based on the original NPRM, another round of comments and responses is not necessary.

Mark

[KevinMcGuire 0]

Well, It seems that I've caused quite the shit storm so, in the interest of lively debate, heres another log for the fire.

Below is a direct quote from Sandy's 2005 handbook. Look it up if you'd like.

"In the past, many master riggers felt that they were
empowered to undertake almost any task. The attitude
was, “We can lift the TSO label, build a new harness, and
put the TSO label back on.” This is not the case. Just
because an individual has a master rigger license does not
mean he or she is qualified to undertake a complex repair"

Hummm. Thats strange. After all these years, I thought that it was the FAA, not the manufactures that granted me the authority to perform complex repairs, including a repair that may involve lifting the TSO label, patching the tail of a reserve canopy or repairing a harness, and then putting the label back in place when I'm finished . Keep mind, I said repair. NOT ALTERATION.

According to Sandy's manual, I can't do any major repair involving a TSO label unless he or some other manufacture gives me the green light.

I wonder. If I replace a damaged main lift web, using the exact same materials, from the exact same source the original manufacture received their material's, complete with the exact same quality control testing certifications the original manufacture received and, I perform the repair in precisely the same manor the manufacture intended when they first manufactured the main lift web, right down to the stitch per inch and, I conform to all the requirements of maintaining all the proper/required records,(just like the manufacture) how is that not in keeping with the per view of my certification?

Since when does any manufacture have the authority to tell me that I can not perform the duties of my certification granted to me by the federal government?
Sounds to me as if the wolf (AKA DPRE)is trying to run the chicken coop

[timmyfitz 0]

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So there you have it.

ehh..nope I already had it.

Obviously not if you quote an AC as if it's regulatory.

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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.

[mark 102]

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[Y]ou quote an AC as if it's regulatory.

You're right, an AC is an Advisory Circular. On the other hand, an Advisory Circular is intended to give a plain language summary of the FAA's understanding of the published regulations. To the extent it is an accurate summary, best practice would be to treat it as if it were a regulation.

Mark

[councilman24 36]

If your post was serious, and I hope it wasn't....

Your taking Sandy to litterally. He doesn't mean that you can't unstitch a TSO label to do a repair and replace it. He means that you cann't take a TSO label off a harness, create from scratch a new, copy harness, and put that original label on it. We often joke about some antique aircraft that all that is left is the original data panal. The skin, ribs, engines, controls, landing gear, etc may all have been 'repaired' by replacing them. He was applying the same kind of comment to parachute equipment.

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

[JerryBaumchen 1,046]

Hi Terry,

NOTE: I am not trying to put words into Kevin's mouth.

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If your post was serious, and I hope it wasn't....

I think he was very serious. Consider that a Master Rigger can replace ( as in repair ) one portion of a harness, then why cannot he just keep right on going and 'repair' the entire harness.

This is the very gray area about the rigs.

The other problem ( IMO ) is that one FAA person will say one thing to a rigger & then another FAA person will say just the opposite to another rigger. And if anyone tries to force the interpretation out of the FAA they just send into the black hole that is in Washington, DC; never to be heard from again.

At the end of the day, none of us can speak for the FAA. None of us have that authority. We can only present our thoughts on this stuff.

Just some thinking on my part . . .

JerryBaumchen

[councilman24 36]

The same FAA headquarters official will tell two different people two opposite things. (Personal experience) Doesn't take two FAA field inspectors.

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

[billvon 2,380]

>According to Sandy's manual, I can't do any major repair involving a
>TSO label unless he or some other manufacture gives me the green light.

I think he was saying that "you can't do any major repair you're not qualified to do." That just seems like common sense. Not all master riggers have the skills or equipment to do all repairs.

[RiggerLee 61]

I remember when Booth caught that guy rebuilding his tandoms and was all kinds of pissed saying that he couldn't do that. But the thing is there are all kinds of presedents for it. By the time the Vin Fizz, first plane to fly coast to coast, landed in CA there were only half a dozen parts on it left over from the original plane. It had been replaced bit by bit. An even better example is today when some one crashes a plane or sinks it in a lake. They will go out with a snorkal, mask and tin snips. They cut out the little plate on the tail and repare the plane around it. I froget the exact rules governing how they do it. tecnicaly the don't repare it all at once. It's done in several stages but in the end it's an airplane once again. And if you weren't permited to do this then frankly GA in this country would be dead. My point is there are presedants.

Now haveing said all that I'm actualy against it. And all though I never bothered to get my master I'm actually one of the relatively few people who could do it. If it had been me I honestly don't think Booth could have spotted it. The thing is it's not simple about being able to do the repare. The TSO is more then just a lable. It's a whole program of quality control, materials tracking, and construction. There's actualy a pretty good stack of paper work assocated with each rig through whitch every peace of fabric, webbing, hardware, grommets, pins, cable... All the way down to the thread can be tracked back to the sorce and even there tracked to it's very lot. And even then, even if you could and would do all that, at the factory they are working from a construction manual. And the product they produice has been checked and inspected to match the line drawing submited to the FAA during testing. And furthermore they are reguarly reinspected by the FAA to conferm that there production has not changed and still matches the line drawing and is in compliance with their approved construction manual.

So in that sence I think I can actually make a good argument that major repares at least those requirering the replacement of matereals should not be done in the field.

Now that's just totaly fucking impractical. But at some point I think we need to address this kind of question. I don't think it's pratical to write it into the FAR's. A publication like Sandies book approved by the FAA as standard practices is the obveous solution. As to his book, well it is his book, who's oppionions do you expect to find in it? It's his standards. Maybe a rigging commity from PIA should jointly write the next one. Good luck with that. In the mean time, he did it. He sat down and did some thing that was twenty years over due. I think it could have been done better but you see how I write. Now you're stuck with it. I think it's fair to say that it's now the offical standard in the industrey. so you'd better get bussy and learn how to use a desk top pubblisher.

Lee

Lee
[email protected]
www.velocitysportswear.com

[councilman24 36]

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Now that's just totaly fucking impractical. But at some point I think we need to address this kind of question. I don't think it's pratical to write it into the FAR's. A publication like Sandies book approved by the FAA as standard practices is the obveous solution. As to his book, well it is his book, who's oppionions do you expect to find in it? It's his standards. Maybe a rigging commity from PIA should jointly write the next one. Good luck with that. In the mean time, he did it. He sat down and did some thing that was twenty years over due. I think it could have been done better but you see how I write. Now you're stuck with it. I think it's fair to say that it's now the offical standard in the industrey. so you'd better get bussy and learn how to use a desk top pubblisher.

Lee

We have recently been expressly told that neither Poynter's books nor the FAA manual that Sanyd wrote are 'accepted or approved'. Because they didn't go through legal at FAA. They ARE the references for most of the FAA written rigger test.

The FAA office in charge has asked for funding to have the FAA Rigger Manual rewritten. It is waiting on funding. The process for this time is up for grabs but I have suggested that a wider input would be helpful.

The FAA manual is NOT the official standard of the industry, but unfortunately some folks, including some in the FAA, are taking it that way. Which was one of my fears when it came out. That FAA inspectors would hold it up as the ONLY way, instead of one way.

More to come.

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

[feuergnom 22]

after reading all this (and it is a great read with heaps of information!) i have come to relise that the things in my corner of the woods (rigging-wise) are rather simplistic if not pathetic - everybody feels entitled to do what he pleases and the authorities are f*****g clueless
even if some of you might bitch & moan on how unclear things are (should we stick to poynter, reid or the FAA?): at least you are able to discuss things on high standards and "cowboy-riggers" seem to be the exception rather than the norm

The universal aptitude for ineptitude makes any human accomplishment an incredible miracle

dudeist skydiver # 666

[riggerrob 558]

" ... Hummm. Thats strange. After all these years, I thought that it was the FAA, not the manufacturers that granted me the authority to perform complex repairs..."

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

The FAA may grant you a license to maintain parachutes, but repair standards are always written by manufacturers.
Repair standards differ from one parachute manufacturer to the next.
FARs always loop back to "maintain in accordance with manufacturer's instructions."
That is a polite way for the FAA to admit that manufacturers know far more about their product than any government bureaucrat.

[riggerrob 558]

"

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... I wonder. If I replace a damaged main lift web, using the exact same materials, from the exact same source the original manufacture received their material's, complete with the exact same quality control testing certifications the original manufacture received and, I perform the repair in precisely the same manor the manufacture intended when they first manufactured the main lift web, right down to the stitch per inch and, I conform to all the requirements of maintaining all the proper/required records,(just like the manufacture) how is that not in keeping with the per view of my certification?
..."

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

Your scheme would only work if the repairs were blessed by one of Rigging Innovations' TSO Inspectors.
For example, I repaired, re-sized, updated, modified etc. hundreds of Talon harnesses while working at Rigging Innovations, BUT every one of my repairs had to be inspected (by the same production inspectors ...) before it shipped.
Then the repair paperwork went into the same archive as the production paperwork.

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[riggerrob 558]

I tell my CSPA Rigger A candidates "while American FAA FARs, ADs, SBs, ACs, PMPs, etc. are not LAW in Canada, they are considered BEST BUSINESS PRACTICES. If a lawyer for the prosecution can prove that you knowingly ignored an AD, you stand alone in court."

[mjosparky 3]

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BUT every one of my repairs had to be inspected (by the same production inspectors ...) before it shipped.

And if the truth be known that “same production inspector” is the same person who made the repairs.

Sparky

My idea of a fair fight is clubbing baby seals

[masterrigger1 2]

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According to Sandy's manual, I can't do any major repair involving a TSO label unless he or some other manufacture gives me the green light.

That is only true for modifications and alterartions.
You have to have approval for those.
I am away for a couple of weeks and do not have all of my resorces here , but it is spelled out in the Inspector's hanbook and a couple of other places.

You are well within your certificate when performing repairs, minor or major.

Again, the manufacture cannot increase or decrease your FAA privleges with regards to limitations

You can legal replace everything except one part or componet and be legal.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com