Interchangability of TSO'd Components

[firemedic 7]

I'd like to start a discussion with riggas about the interchanging of major components.

[riggerrob 558]

Last time I read the FARs, FAA Master Riggers were allowed to interchange "similar TSOed components" between similar rigs.

On a practical level, that means that many main components can be interchanged. For example, since most sport rigs now have mini-risers and mini-rings, it is easy to interchange main risers. The only compatibility question is "are those cutaway housings long enough to be compatible with Aerodyne's mini-force risers?"

Most throw-out, main pilot chutes can be intechanged between containers with similar BOCs, so the only hassle is when interchanging pilot chutes between rig with different pull-out pockets.

However, interchanging reserve components gets far more complex, with far more compatibility questions. The simple answer for junior riggers is: "Don't interchange reserve components."

A few reserve containers are so similar that reserve components can be interchanged (eg. installing Vector components in Eclipses). But sometimes answers to compatiblity questions sound more political than practical. For example, if you ask Mike Furry (owner of Altico and half of the original design team for the Javelin), it is okay to install Dolphin freebags and pilot chutes iin Javelins, but if you ask Sun Path (aka. the Javelin factory) you can only legally install genuine Sun Path parts in Javelins.
I cannot tell the difference at arm's length.

If you assemble components certified under two different TSOs, the you degrade the equipment to placarded airspeed and weight limitations of the lower performance TSO.
And to the critics, main components were not mentions in earlier versions of FAA TSOs (TSO C23B), but they are mentioned in later versions (eg. TSO C23E)

[firemedic 7]

I just ran into that issue with a dolphin. A guy bought a Dolphin D2 and it came with a javelin PC and an Infinity freebag. The guy who sold it to him said he is a master rigger and says the parts are compatible. I've been a rigger for a year and a half so I started asking questions. I spoke to Furry. He said that a rigger could make that determination based on AC105-2c. I'm not willing to make that decision, i.e. pack the rig that way. All the riggers I trained under always told me to use only parts made for a particular rig. You just told me the same thing. I think I'm going to heed yours and thier advice.

[mjosparky 3]

This is what AS8018-B has to say about it.
Sparky

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5. COMPONENT QUALIFICATIONS:

5.1 Parachutes may be qualified as complete assemblies or as separate components (such as a canopy, a stowage container [pack], and/or a riser. The airworthiness of a parachute assembly, including other separately approved nonoriginal components, is the responsibility of the manufacturer who performs the certificating tests for the parachute assembly. The manufacturer shall publish and make available a list of interchangeable components which have passed the following tests in 4.3 when tested in conjunction with the assembly or component(s) being certificated.

5.1.1 Canopy Including Suspension Lines: 4.3.3, 4.3.4.1 (or 4.3.4.2), 4.3.5, 4.3.6, 4.3.7, 4.3.8, 4.3.9

5.1.2 Deployment Device: 4.3.3, 4.3.4.1 (or 4.3.4.2), 4.3.5, 4.3.6, 4.3.9

5.1.3 Pilot Chute (Including Bridle): 4.3.3, 4.3.4.1 (or 4.3.4.2), 4.3.5, 4.3.6, 4.3.9

5.1.4 Stowage Container (Pack): 4.3.2.1, 4.3.2.3, 4.3.3, 4.3.6, 4.3.4.1 (or 4.3.4.2), 4.3.5, 4.3.9

5.1.5 Harness: 4.3.4.1, 4.3.6, 4.3.9

5.1.6 Actuation Device (Ripcord and/or Reserve Static Line): 4.3.1, 4.3.2, 4.3.6.2, 4.3.9

5.1.7 Actuation Device (Reserve Static Line): 4.3.1, 4.3.6.2

5.1.8 Riser(s): 4.3.4.1 (or 4.3.4.2), 4.3.6, 4.3.9

My idea of a fair fight is clubbing baby seals

[councilman24 36]

And here is AC 105-2C

11. Assembly of major parachute components

A. The assembly or mating of approved parachute components from different manufacturers may be made by a certificated appropriately rated parachute rigger or parachute loft in accordance with the parachute manufacturer's instructions and without further authorization by the manufacturer or the FAA. Specifically, when various parachute components are interchanged, the parachute rigger should follow the canopy manufacturer's instructions as well as the parachute container manufacturer's instructions. However, the container manufacturer's instructions take precedence when there is a conflict between the two.

B. Assembled Parachute Components Must be Compatible. Each component of the resulting assembly must function properly and may not interfere with the operation of the other components. For example:

1. Do not install a high volume canopy into a low-volume parachute container since the proper functioning of the entire parachute assembly could be adversely affected.

2. A TSO'ed canopy may be assembled with a demilitarized harness, or vice versa, as long as the assembled components comply with the safety standard of the original design.

C. Any questions about the operation of the assembly should be resolved by actual tests by the rigger or loft to make certain the parachute is safe for emergency use.

D. The parachute rigger or the parachute loft who are assembling components manufactured under TSO-C23c will record, in the space provided on the container, the data required by Aerospace Standard AS-8015B, paragraph 4.2.1. (Copies may be obtained from the Engineering Society for Advancing Mobility Land, Sea, Air and Space, 400 Commonwealth Drive, Warrendale, PA 15096-0001.)

E. The strength of the harness must always be equal to or greater than the maximum force generated by the canopy during certification tests.

1. In a case where the harness is certificated under TSO-C23b and the canopy under TSO-C23c, the maximum generated force of the canopy must not exceed the certificated category force of the harness and container; i.e., Low-Speed Category (3,000 lbs.) and Standard Category (5,000 lbs.). In this instance, no additional marking on the container is necessary.

2. In the case where the canopy is certificated under the TSO-C23b and the harness under TSO-C23c, the strength of the harness must be equal to or greater than the certificated category force of the canopy.

F. 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 necessary for transportation, handling, or storage between periods of use if the parachute is designed to simplify such assembly and disassembly without the use of complex operations.



But I know very few riggers that would interchange free bags and PC's. Most probably wouldn't interchange toggles or ripcords either.

Rob, it's not in the FAR's but in the AC and it's any rigger with the right rating, chest, seat, back, or lap.

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

[Bertt 0]

Just curious: Did the data card in that rig make any mention of the substitution of non-original parts? Did the master rigger who sold the rig put his signature on anything that said the parts had been exchanged? Would the FAA come looking for anybody but you if you packed the rig that way and they had some reason to inquire about it?

You don't have to outrun the bear.

[JerryBaumchen 1,066]

Hi firemedic,

Interesting question and some good replies ( I hope some others reply also ).

None of us can speak for the FAA or for any given manufacturer unless we work for either one and have authority to do so.

I'll offer my thoughts. Going from memory, the Dolphin freebag has a single grommet that captures the lower face and the top face of the freebag, securing them together. They may also have some stitching above the grommet that further secures the lower face & top face together. I 'think' that the Infinity freebag is rather like a Vector freebag in that the lower face has a grommet set into it & the top face has a grommet set into it, with nothing securing the lower face & the top face together.

To me this is a substantial difference in construction methods and I, personally, would not pack such a setup.

Now, as for how Rob describes the Dolphin freebag vs the Javelin freebag, there is very little difference(s) in construction. I would be much more comfortable using a Javelin freebag in a Dolphin. However I, personally, would not do this. I just don't like that much 'substitution.' But that is just me.

It gets further confusing when, as Rob mentions, the parts are from different TSO standards. I, hopefully, am not picking on Bill Booth with this. Back in 1974, when he TSO'd the Wonderhog, there were no freebags and he did not get a TSO for a reserve pilot chute. In TSO C23b these are not listed as components. Therefore, I am thinking that he did what I did when I added a reserve pilot chute & freebag to what I made; I made them a part of the reserve container, and the FAA was quite satisfied with that ( at least they did not so 'NO' ). Considering this, I would not subsitute an Infinity freebag into a Vector III because the V-III freebag is a part of the container ( I think ). I do not speak for Bill Booth, it is only my thinking & opinion until corrected.

I obtained my first TSO's in 1979 under C23b. They were for a harness and for a container. A few years later I submitted the paperwork for a TSO for a ripcord. When the FAA sent back the approval they inadvertently included some internal office memoranda in which on FAA-guy asked the question of "Just how far down do we go with this stuff?' They were not completely sure if they should grant a TSO for a ripcord.

Just something to ponder.

And as Sparky indicates, the later TSO versions ( C & then D ) have 'deployment device' & 'pilot chute' as seperately listed components; meaning that you can now obtain a TSO for just a pilot chute should you want to do so.

Just my input & some will not agree,

JerryBaumchen

[diablopilot 2]

Quote

A guy bought a Dolphin D2 and it came with a javelin PC and an Infinity freebag. The guy who sold it to him said he is a master rigger and says the parts are compatible.

Ralph?

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

[JerryBaumchen 1,066]

Hi Bertt,

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Would the FAA come looking for anybody but you if you packed the rig that way and they had some reason to inquire about it?

Back in the early '80's I was travelling to Denver a lot on business. At that time J. Scott Hamilton had a private law practice specializing in Aviation Law located in Denver. On a number of occasions I stopped by to discuss liability in this industry with him. I have this aversion to wanting to live out of a shopping cart.

He said that he had quit packing reserves for anyone but himself because the rigger doing so was the last person to do anything officially with the equipment and that he felt that this rigger had the highest level of exposure in a lawsuit ( 'exposure' is legal terminology for 'you're going to get your pants sued off of you' ).

Just a thought regarding your post,

JerryBaumchen

[mjosparky 3]

Quote

He said that he had quit packing reserves for anyone but himself because the rigger doing so was the last person to do anything officially with the equipment and that he felt that this rigger had the highest level of exposure in a lawsuit ( 'exposure' is legal terminology for 'you're going to get your pants sued off of you' ).

It seems that in recent years, last 10 to 15, the shift in law suits has been toward “deep pockets” as in anyone remotely involved that has money. Most independent riggers would not make an attractive target for such a suit. The manufactures and DSO’s that have something substantial to lose I would think have done everything possible to reduce their exposure.

Like you said, just some thoughts on the post.

Sparky

My idea of a fair fight is clubbing baby seals

[tdog 0]

Here is one...

What do riggers think about a PD Reserve Slink being used on a non-PD canopy.

I know one rigger that will use them on any reserve where metal links are approved as they are TSOed and that PD claims in their manual: When properly installed, they are stronger than the stainless steel links they replace., therefore if they are TSOed and stronger then the substitution is appropriate and safe.

I know another rigger that will not pack any non-PD reserve with slinks and sells metal links to the customer and mandates their use as that is "what shipped with the canopy and PD does not approve the slinks on anything but PD."

[riggerrob 558]

Remember that Parachutes de France was the first company to sell modern, re-usable soft links.

Back when PD was the only American company manufacturing "certified" soft links, I vaguely remember PISA saying that it was okay to assemble Tempo reserves with PD SLinks. Precision also said that it was okay to assemble Raven reserves with PD SLinks,
But since then both companies have certified their own soft links, so PD SLinks get used less often in assembling their reserves.

[riggerrob 558]

Quote

...
I'll offer my thoughts. Going from memory, the Dolphin freebag has a single grommet that captures the lower face and the top face of the freebag, securing them together. They may also have some stitching above the grommet that further secures the lower face & top face together. I 'think' that the Infinity freebag is rather like a Vector freebag in that the lower face has a grommet set into it & the top face has a grommet set into it, with nothing securing the lower face & the top face together.

To me this is a substantial difference in construction methods and I, personally, would not pack such a setup. ..."

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

To further confuse you, early Infiinity free-bags were built similar to Dolphin/Javelin free-bags (sewn together int eh middle, with only one grommet), but later Infinity free-bags are built more like Vector freebags (not sewn together in the middle, with two grommets).
So installing a free-bag form an early Inifinity might be okay, but installing a free-bag from a recent Inifinity might be a bad idea because the grommet configuration is considerably different from the Dolphin/Javelin configuration.

Did that muddy the waters for you?
Hah!
Hah!

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[firemedic 7]

I really appreciate everybodys input. First to answer BERTTs question about the data card. It was missing from the rig so there is no history for the rig. I advised the owner that it needed to go to Altico anyway because it needs an update, the base plate in the reserve container. It has the old plastic one and needs the metal one. Also, with no history for the rig it can be thoroughly inspected and any other updates performed. As for the rest of the discussion, It is my understanding of The AC that either master or senior riggers can combine components from different manufacturers if they follow all the rules. Anyone else have an opinion on this please share. I agree with whoever said lawsuits focus on "deep pockets", I don't think they'd want my pos 98 corolla. They'd probably end up pushing it to court anyway. But I would'nt put it past a lawyer going after a manufacturer for not prohibiting the use of substitute parts in their equipment. Javelin prohibits the use of any other reserve pc than theirs. If there is ever a fatality investigation that shows a reserve pc and/or freebag from different manufacturers were used, it is likely for that to become a neglegence issue.

Stir the pot and the dregs will stay evenly distributed

[riggerrob 558]

I was always under the impression that FAA Senior Riggers were allowed to substitute main components, but only FAA Master Riggers were allowed to substitute reserve components.

That being said, field riggers get the opportunity to substitute reserve components, because so few reserve components are substitutable.
For example, only Advance, Concept, Dolphin, Genesis, Vortex, Wings reserve pilot chutes will work with Javelins and I am willing to bet that the Vortex pilot chute will look butt-ugly!
Ergo, most of the time, it is simpler to order a new Javelin pilot chute form the Javelin factory.
Oh!
And if I see one more rigger jamming Javelin pilot chute fabric under the cap - with a packing paddle - I am going to use that packing paddle to jam .... under his ....!!!!!!!

[firemedic 7]

Rob I with you on the issue of jamming javelin PC fabric under the cap with with a paddle. I have found holes in PCs, as no doubt you have as well. There is no excuse for it. I may have beat this horse to death but it just seems to me the FAA loves the color gray. AC105-2c paragraph 11 it seems to allow "A certificated (Senior or Master) and appropriately rated(back, seat, Chest) rigger to make the determination. I'm a senior rigger and I have only been one since Jan 09. I still have a lot to learn which is why I'm raising the question. I've done over 150 repacks since becoming a rigger and I've seen things that makes me scratch my head and I've called rigger friends and manufacturers on numerous occasion. I've found reserves with 3.5 Rapide Links and every manual I've read says 4s 5s or if the reserve manufacturer has approved slinks they can be used. I just repaced some 3.5s with SR1 on a PD reserve on Sunday. The rig had been assembled in 2000. No notes on any link changes so I assume it was assembled that way. I did varify with PD that only Mallion Rapide SS#4 or SS#5 or SR1 slinks can be used with their reserves. Maybe this question merits a new thread. Your thoughts.
v

[riggerrob 558]

Quote

Rob I with you on the issue of jamming javelin PC fabric under the cap with with a paddle. I have found holes in PCs, as no doubt you have as well. There is no excuse for it.

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

Agreed!
And you only find damaged reserve pilot chutes - at midnight - before the big boogie!
Hah!
Hah!
The last time we found a damaged pilot chute - on a Javelin - we sold him a Dolphin reserve pilot chute.

If only riggers would read the Javelin packing manual written in this century! I struggled to make Javelin pilot chutes look pretty - until the latest manual - and now use that method to pack all semi-Pop-Top pilot chutes. The new method is so much more graceful!

• Quote

[Deyan 31]

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I've found reserves with 3.5 Rapide Links and every manual I've read says 4s 5s or if the reserve manufacturer has approved slinks they can be used

Aerodyne has TSO'd for their Smart with Rapide links # 3,5 and #4

"My belief is that once the doctor whacks you on the butt, all guarantees are off" Jerry Baumchen

[RIGGER 0]

The French 3.5 rapid links were never TSO'd on any reserve.

Only No.4,5 & 6 were TSO'd by specific mfg. for round or ram air reserves.

No.4 in SS only by PD, #5 & 6 are use on reserves / PEP in the steel version too.

The link itself is not TSO'd - only when arrived from the canopy mfg. which tested these specific links.

I mean: # 4 & 5 for PD reserves MUST be from PD & same for other mfg. - the links goes into a QC process & approved by the reserve mfg. according to QC spec. also clean up & most times sharp chips / burr surface are removed as well - but always check that.

The metal links has some cons like sharp / burr / chips on the SS links which might damage the reserve riser / lines & the closing process of the threads & sceuring with Loctite.

When using metal links use silicon / fabric bumpers (PD on # 5) & hand tack to the link by the mfg. instructions.

Be Safe!!!

[RIGGER 0]

The h/c must have the h/c mfg. free bag/bridle & reserve p/c to be legal to I&R and be jumped.

Reserve free bags & reserve p/c are approved & TSO'd only when used with the original h/c they were test & approved for. The size of the free bag must match the reserve container size & the reserve packed in.

Dolphin D2 must be used only with ALTICO D2 free bag & ALTICO reserve p/c & riggers can NOT change that.

I hope that helps & all is IMO & the way I would act.

Cheers!!!

[Deyan 31]

Quote

The French 3.5 rapid links were never TSO'd on any reserve.

Hi Shlomo,

As much as I respect your knowledge ,I have to disagree with you on this one.
A few months ago I had a Smart reserve with # 3,5 links for I&R. The first thing I did after I saw them was to contact the manufacturer and ask about them...

Here is the answer:
Hello Deyan,
The Smart is TSO'd with 3.5 and #4 links as well as softlinks.


Blue skies

"My belief is that once the doctor whacks you on the butt, all guarantees are off" Jerry Baumchen

[RIGGER 0]

If it is as you say, I wonder why Aerodyne did that - yes, I never met a reserve with #3.5 metal links - all Smarts here have Soft Links.

It's sound not logic testing for the TSO with #3.5 & 4 when #4 is stronger & fits better into the risers.

It is more logic to be TSO'd with #4 & 5.

I would not pack a reserve with #3.5 & I would ask the owner to change for Aerodyne Reserve Soft links.

Cheers

[Deyan 31]

Quote

I would not pack a reserve with #3.5 & I would ask the owner to change for Aerodyne Reserve Soft links.
Cheers

It's what I did anyway
Blue skies

"My belief is that once the doctor whacks you on the butt, all guarantees are off" Jerry Baumchen

[percy 0]

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This is what AS8018-B has to say about it.

AS8018-B!! ....sorry but but it isn't AS8015-B

[riggerrob 558]

Quote

If it is as you say, I wonder why Aerodyne did that - yes, I never met a reserve with #3.5 metal links - all Smarts here have Soft Links.

It's sound not logic testing for the TSO with #3.5 & 4 when #4 is stronger & fits better into the risers.

...

Cheers

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

Agreed!
#6 Maillon Rapide links fit best on risers made of Type 7 webbing,
#5 links fit best on risers made of thinner Type 8 webbing.
#4 links fit best on risers made of narrower Type 17 webbing.
But trying to assemble tiny #3.5 links on reserve front risers made of thick Type 7 webbing ???? that is doing it the hard way.
Most modern reserves get assembled with soft links these days.