65.111 Revised

[jonmurrell 0]

Stupid questions from a youngster: how does this relate to maintaining and altering mains? Is the main technically part of the parachute (the part that requires certificates)?

Advisory Circular 105-2C, Sec. 6 states: "In the case where the harness and parachute are TSO-approved as an intended component, the term pack refers to the complete parachute assembly, less the main canopy and risers. This distinction is essential for a clear understanding relating to the use, packing, repairing, and alteration of parachutes."

105-2C also says that, "the user of a single harness, dual pack parachute system, which is a sport assembly consisting of a main and auxiliary/reserve parachute, may perform simple assembly and disassembly operations [...]" is there any further guidance on simple assembly/disassembly of already approved components?

Stupid questions complete. For now

edit for a: "?" mark

This isn't flying, its falling with style.

[theonlyski 3]

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You know, following the logic of your post, pretty soon you'll have to get an FAA certificate to pack a main. After all, a non-certified individual could pack themselves a line over.

So could a certified one.

"I may be a dirty pirate hooker...but I'm not about to go stand on the corner." iluvtofly
DPH -7, TDS 578, Muff 5153, SCR 14890
I'm an asshole, and I approve this message

[diablopilot 2]

Cue sarcasm.

----------------------------------------------
You're not as good as you think you are. Seriously.

[Zymurdoo 0]

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I laugh every time a (non-rigger) fun jumper asks if he can use my rack to assemble his new main. Three hours later - and multiple mis-routings - they admit that it would have been quicker and simpler if they had just asked me to assemble it.

Rob Warner
FAA Master Rigger (back, seat and chest)
Canadian Rigger Examiner
Strong Tandem Examiner

Wow, really. My rigger as well as other instructors taught me how to do this when I was on student status. I also learned how to do a line check too. Thanks Poor Old Rigger Bob and all the others that have saved me "three hours" every time I had to reassemble my rig.

Blue Skies, Soft Docks and Happy Landings!
CWR #23
(It's called CRW, add an e if you like, but I ain't calling it CFS. FU FAI!)

[riggerpaul 1]

Good or bad, and AC-105 notwithstanding, 65.111 says that a certificate is required to repair or alter a main.

I do find it interesting that AC-105 says, "Parachute alterations are changes to the FAA-approved configuration."

If a main parachute has no FAA approval, how can it have an FAA-approved configuration?

If an alteration is a change to an FAA-approved configuration, and a main has no FAA-approved configuration, this appears to say that alteration of mains is not considered alteration at all.

Some of the people posting here are quite clear that we must look to the supporting documentation to understand the intent of the regulations.

Looking at some of what is in AC-105 might lead a person to believe that mains are not covered by the requirements to have riggers work on them.

If we are to look at the supporting documentation to determine the intent of the regulation, what do we do when the supporting documentation seems to add confusion instead of clarity?

A new version of AC-105 is supposedly in the final stages of review before publication.

It will be very interesting to see if the new version clarifies or further confuses these issues.

[masterrigger1 2]

Paul,
Real quick as It is Saturday AM and I am actually headed out the door..or was!

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I do find it interesting that AC-105 says, "Parachute alterations are changes to the FAA-approved configuration."

If a main parachute has no FAA approval, how can it have an FAA-approved configuration?

If an alteration is a change to an FAA-approved configuration, and a main has no FAA-approved configuration, this appears to say that alteration of mains is not considered alteration at all.

The definition of an alteration is a change from the original manufactured design or configuration.

The definition of an approved alteration is changes to the orginal FAA approved configuration.

The rule and it's intent, trump AC's anyway, so it is a moot point.

***

A new version of AC-105 is supposedly in the final stages of review before publication.

It will be very interesting to see if the new version clarifies or further confuses these issues.

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I hope to get my hands on the newest version this coming week.

I do know that there is language that is going to kick it out of Legal for a couple of reasons.

One is this new clarification and fix.

Cheers,

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

• Quote

[riggerpaul 1]

The point is that there's conflicting information everywhere.

You seem to know what trumps what, but sometimes you say that the rules trump other docs, and other times you say other docs trump rules.

While it is great that you have the direct line from god on this, the rest of us mortals have to read the docs and try to figure it out.

[riggerrob 558]

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I laugh every time a (non-rigger) fun jumper asks if he can use my rack to assemble his new main. Three hours later - and multiple mis-routings - they admit that it would have been quicker and simpler if they had just asked me to assemble it.

Maybe you should be teaching them how to do it properly.

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

I have offered to host "Know Your Gear" seminars, but only one skydiver showed up.

• Quote

[councilman24 36]

It's not my logic! It's the FAA's and their regulations since they came into existence. THEY are willing to let the next guy pack it. Nothing else. But they don't require documentation of who did what on a main. 2001 to 2010 language was their mistake and they never changed their intent. If you don't want to follow the law that's up to you. Lots and lots of folks don't and haven't over the years.

I have never stated what I think the regs should be. It's not my logic and it's not my opinion.

I will state that I don't think anyone but a rigger should be working on a student or tandem gear. What is 'working'? Might be up for debate but but lots of simple things have been done wrong.

I don't think I ever did hear why you think just having a rigger's ticket was a liabity.

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

[masterrigger1 2]

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The point is that there's conflicting information everywhere.

It seems that you are the only one that has that issue.

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You seem to know what trumps what, but sometimes you say that the rules trump other docs, and other times you say other docs trump rules

I would have to say that I have educated myself over the years with the MANY discussions with Legal. If a rule has no preamble or definition then a AC can provide some clarity.
If a rule has a complete preamble with the rule's complete intent, such as this one, this is no need for an AC. The AC that you are quoting predates this rule. That's the trump.


***

If you are calling the the FAA, God, then yes I do!

I do not think there is anything to figure out. The rule, not an AC or any other document prety much sums it up.
Also,I have contacted Washington about putting "appropriate" in sentence 2 for you.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[tdog 0]

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As to fatalities due to noncertified maintenance. First, we'll never know in most cases if bad maintenance was by a rigger or someone else because there is no documentation needed and the owner is deceased and can't tell us. Here is a quote from USPA incident report.

"Several fatalities have been attributed to interference between the steering controls and slider grommets at a low altitude...

Terry,

I am not trying to attack you personally, however I am going to ask you to back your previous statement that maintenance has killed people.

The FAA published in the Federal Register that MEL linked to this thread:

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The parachute industry raised concerns that
the resulting authority language in the
2001 amendment could be viewed as
authorizing maintenance or alteration
by non-certificated persons not under
the supervision of an appropriate
current certificated rigger. Those
concerns pose significant safety
concerns for the FAA and those
regulated by § 65.111.

Emphasis added by me.

We will never know who in "the parachute industry" made these recommendations to the FAA, but I know PIA communicates to the FAA a lot, and so do you and MEL as you had a meeting earlier in the year at MEL's loft with the FAA. In fact, moments ago in another post MEL posted he sent a note to the FAA today... Perhaps in your conversations these matters came up and the FAA expressed concerns?

So in a previous post, I asked for data (maybe a list) of fatalities or serious incidents that were the basis for the claim that there is a safety risk. Specifically I asked you because you said that improper maintenance has killed and you cited a list MEL had.

I appreciate your reply post about USPA's concern about sliders/canopy attachments/toggles as an example of a safety risk. I can testify I have seen, and experienced, malfunctions in these components that have required "crash landings on rears" or reserve rides... In most cases, the gear was assembled by a certified individual, but the inherent design flaws in the keepers to stow excess line, the ability or desire to pull the slider down past toggles upon demand, but not on opening, etc - all have a lot of risk... I think this is known by most people with a handful of jumps because most people can tell you about their brake malfuction they once had.... However, this is really assembly and product procurement and design flaw issues, not maintenance, alterations or repairs....

But, since you posted that MEL has a list of work done to canopies that has killed, and you have posted that maintenance has killed, do you have any other areas we should look for when we see our friends/customer's rigs beyond the toggles/sliders?

Yes, I am calling your bluff since you posted a comment as it was a fact. I am seeking the data behind your comment, if it exists.

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First, we'll never know in most cases if bad maintenance was by a rigger or someone else because there is no documentation needed and the owner is deceased and can't tell us.

Very valid point... But, for the sake of discussion, which fatalities are you talking about, regardless of who did the work, because maybe we can learn and identify trends?

I am looking for things like improperly installed lines, patches or repairs that failed.... Not things like trashed linesets that the user failed to attempt to repair or hire for repair, but actual poor workmanship in attempted repairs. I want to use that data to see if it was improper tools, improper training, or something else that caused the fatality...

Thanks for your time, I look forward to your response. FYI, just today I, thanks to your post about slider/toggle issues, walked up to a fun jumper I did not know well and expressed concern about his risers... He ended up replacing them on the spot. It is a good thing to look for this time of year in the spirt of spring cleaning.

[councilman24 36]

Not ignoring you. Haven't been on much and will take time to compose a response. Single parent this week.

But, most of the maintenance I refer to is assembly or replacement of components. MEL has the details of line replacement. I heard it from him. It's not going to be sewing a patch. And I'm not going to have a list.

One real fast. A guy bought after market toggles from someone at Richmond one year and put them on. They were built/designed wrong and were able to be sucked through the ring. A guy went into a tree under a spinning main and jammed a branch into his butt cheek. Very deep. If it hit his femoral artery or abdomen he may have died. Couldn't sit for a couple of months.

I recognized the flaw in these toggles right away when I saw them. A less experience rigger rigger might not have. And the guy with a few hundred jumps (the user) never would.

People have stitched into reserve canopies. I don't remember if it caused an injury or fatality but frankly I don't really care. If it could have it's a mistake and wrong. We're lucky that most main problems DON'T result in injury or death and never make it into a report. I've watched several mains but on backwars. Some landed some cutaway. Does this count to you? It does to me. Anything that makes you use your last chance to live is serious. I'll tell you about one of these later. It was hilarious.

I predict you are not going to be satisfied with whatever I might be able to attribute to a death or injury. But again, it doesn't have to to me.

More later.

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

[AggieDave 6]

And how many reserves have you pulled out that had a molar strap or something routed wrong? How many table totals have you pulled apart?

Even the grand-wizards of the nylon world make mistakes.

--"When I die, may I be surrounded by scattered chrome and burning gasoline."

[tdog 0]

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I predict you are not going to be satisfied with whatever I might be able to attribute to a death or injury. But again, it doesn't have to to me.

No, I am already satisfied. Can you perhaps, when you have time, give more data on the toggles you mentioned, in addition to other gear failures?

I actually was shipped a set of toggles from a manufacture with a completely new rig, that I could get to "malfunction" 75% of the time because a bartack was not in the right place... So did the end user on 75% of their jumps... The manufacture told me, "oh, we had a new employee making those. We thought we removed the bad ones from inventory." Basically the tab had an area of no bartacking in the middle where the brake line loop would normally rest when stowed for deployment, thus the tab could squeeze and be squished in that area and trap the brake line by friction with a small bump. On opening the tension of the line would dig into the toggle, and when the toggle was released it would not release the line from the tab. It required both hands to pull the line from the tab once tension from the canopy was applied, which would cause a novice skydiver to cutaway when the canopy would uncontrollably turn until they realized what happened. So now I inspect all toggles for the "softness" where the loop of brake line will sit for deployment.


But, I think you said what I believe yourself:

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But, most of the maintenance I refer to is assembly or replacement of components.

I think we are in total agreement that the majority of the risks to end users are not in the repair/alterations of mains, but instead the assembly of parts and/or design flaws in the parts.

I think most skydivers want the freedom to do "light maintenance" and/or "assembly" of their mains, and I think most people agree this is allowed by the FARs, or as others posted, should be allowed in a three tier system of "user" - "senior rigger" - "master rigger".

So I don't think us riggers should be advocating increased regulation on assembly of mains because of a few incidents, because sooner or later, mains will have to be packed by riggers because I don't think the FAA will know where to stop when they add more regulation.

The solution has to be in self regulation, because if we tried to regulate all assembly by the FARs, installing threerings would be rigger only, and so would installing rubberbands... And I don't think we would change the incident rate much...

And, maybe your point shows that we need a tad of a culture change in the rigging industry where riggers spend a tad more effort on the main instead of slamming the reserve into the rig and moving on. We inspect the reserve over and over again, even though it sees daylight for only an hour twice a year, but how often do riggers ofter to inspect the main without demanding additional money?

[NovaTTT 1]

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We inspect the reserve over and over again, even though it sees daylight for only an hour twice a year, but how often do riggers ofter to inspect the main without demanding additional money?

I agree with the concept of further self-regulation. We need more federal oversight like we need a bag on our hip.

What is needed from the FAA is clarity. This is what MEL is working on, I believe. It's a shame the FAA screwed it up - 65.111.c.2 shouldn't be ambiguous on Day 1!

But to the matter of mains and inspection:

Should a rigger spend an hour every 180 days inspecting the main as he does the reserve? For "good will"?

I say, "no". The user has the opportunity to and should keep tabs on what is going on with his main - if not on every jump then at least on the first or last jump of the day.

There is not much room for excuses if a jumper doesn't keep up with his gear. Even those who use packers can slip an extra fin to the blackfeet to have them give a good eyeball to the kit while packing.

But we inspect and carefully pack the reserve because when called upon we intend it to open without fail. A failure to deploy, given sufficient altitude, is a failure of the rigger, excepting non-rigging entanglement.

Regardless - I'm happy to do a main inspection and repack when a rig comes in for A.I.R., for reasonable compensation. "Reasonable" is cheap, too - I'm not rigging to get rich, that's for sure.

The rigs I A.I.R. are returned to the jumper with the main unclosed if they do not want the main inspected and packed. If it comes to me with the main deployed, however, I'll pack it up. It makes things easier, frankly.

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

[mark 102]

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A new version of AC-105 is supposedly in the final stages of review before publication.

It will be very interesting to see if the new version clarifies or further confuses these issues.

I hope to get my hands on the newest version this coming week.

I do know that there is language that is going to kick it out of Legal for a couple of reasons.

One is this new clarification and fix.

Cheers,

MEL

As you know, I wrote most of the PIA's proposed changes to AC 105-2. You know that because I included you in the initial distribution almost a year and a half ago. I invited you then to make contributions to subsequent drafts, and you have had lots of opportunities to comment since, but this is the first time I've heard you suggest there is un-Legal language in our proposal.

Discourteous is one word that comes to mind.

What specific language do you think is problematic, in the latest or previous revision proposals?

Cheers,
Mark

[masterrigger1 2]

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As you know, I wrote most of the PIA's proposed changes to AC 105-2. You know that because I included you in the initial distribution almost a year and a half ago. I invited you then to make contributions to subsequent drafts, and you have had lots of opportunities to comment since, but this is the first time I've heard you suggest there is un-Legal language in our proposal.
***

Mark,
The same items that I responsed with right after I received your copy.

I can resend the email to you later.

***
Discourteous is one word that comes to mind.

As I stated above I did make a reply.

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What specific language do you think is problematic, in the latest or previous revision proposals?

I am not in the shop right now. That stuff in on one of the computers there.
I will reply in-depth later....Probably start another thread with it.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com