Cypress +/- 6 Months?

[riggerpaul 1]

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I'm familar with the requirements to follow the manufacturers instructions. That's valid for any kind of certificated parachute equipment.

I could swear I remember a time when Cypres allowed their units to stay in service until the next repack. Was that a change or a misunderstanding in the field. Seems in my memory it was that way for a while.

There was a time when there was no mention of any AAD in FAR 105, and I suppose that, at that time, you might play fast and loose with manufacturer's requirements.

But since the revision of FAR 105 that included those items in 105.43 and 105.45, it has been absolutely clear that the manufacturer gets to tell us what must be done in order to maintain airworthiness.

That's been since some time in 2001, IIRC.

Now, exactly what Airtec said was required may have changed some over the years. I have no particular knowledge about that. So somebody else will have to jump in with those details.

[masterrigger1 2]

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But since the revision of FAR 105 that included those items in 105.43 and 105.45, it has been absolutely clear that the manufacturer gets to tell us what must be done in order to maintain airworthiness.

Paul,
It is about as clear as mud.
In reality the H/C manufacturer is supposed to inform us of the requirements, not the AAD manufacturer as they are not the TSO holder.

Since the Units are not TSO'd, the only legal way to include them is by way of the H/C manufacturers including the units as "required or approved materials". They do that by writing them into their TSO paperwork. Once they do that, the H/C manufacturer takes ownership of instructions for use of their TSO equipment.

So in reality, the H/C manufacturers are supposed to have any maintenance requirements in their manuals.

But we seem to be not doing it in that fashion.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

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Not the part that states that OTHER riggers can open and close someone else's pack job to change batteries.

Taken from TB-252 v1.1:

"NOTE: A rigger may elect to re-close, sign, and reseal only a reserve that they originally packed. " (emphasis added.)

Perhaps other riggers were not excluded in v1.0, but PIA now indicates they consider it the job of only the rigger who sealed the pack job to open it for maintenance, without performing a full AIR.

But they don't pretend it doesn't happen:

Also from TB-252 v1.1

"NOTICE: Before opening and re-closing a container packed by another rigger, careful consideration should be given to any and all legal ramifications."

My interpretation of this is quite different from yours.

The way I read it, they are just specifically mentioning that we can choose to restrict ourselves to rigs where we did the most recent repack, if we like.

Here's the whole answer, for reference
(I also broke the paragraph into sentences so they are easier to notice.)

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Yes.

The reserve container may be opened, re-closed, and resealed to permit scheduled or unscheduled
maintenance or repairs (for example, AAD service or closing loop replacement) within the 180-day or 60-
day period as applicable.

The rigger who reseals the container is responsible for the airworthiness of the
parachute system at the time it is returned to service.

Important: mid-cycle maintenance does not alter the next repack due date; notations on the packing data card must clearly indicate this to avoid confusion by parachute users.

NOTE: A rigger may elect to re-close, sign, and reseal only a reserve that they originally packed.

NOTICE: Before opening and re-closing a container packed by another rigger, careful consideration should be given to any and all legal ramifications.

The first 3 sentences are clear that you can open and re-close, and that you might not be the one who closed it last.

Regarding the "NOTICE", they are not telling us to think hard about breaking the law before we do. They are telling us to carefully consider not using this provision of the law.

[riggerpaul 1]

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But since the revision of FAR 105 that included those items in 105.43 and 105.45, it has been absolutely clear that the manufacturer gets to tell us what must be done in order to maintain airworthiness.

Paul,
It is about as clear as mud.
In reality the H/C manufacturer is supposed to inform us of the requirements, not the AAD manufacturer as they are not the TSO holder.

Since the Units are not TSO'd, the only legal way to include them is by way of the H/C manufacturers including the units as "required or approved materials". They do that by writing them into their TSO paperwork. Once they do that, the H/C manufacturer takes ownership of instructions for use of their TSO equipment.

So in reality, the H/C manufacturers are supposed to have any maintenance requirements in their manuals.

But we seem to be not doing it in that fashion.

Cheers,
MEL

One of the purposes of the way it is written is to take the responsibility for the AAD away from the rig manufacturer, and place it clearly in the hands of the AAD manufacturer.

It doesn't matter if the gear is TSO'd or not. The notion of airworthiness is not just a legal term for the FAA. Just because the FAA has no standards of its own for airworthiness of an AAD does not mean that the manufacturer cannot have his own.

If the manufacturer says it is not airworthy, the FAA has no problem with agreeing.

You have already made your position very clear that the regulations include both certified and non-certified equipment.

A manufacturer, inspecting a main canopy they made, already has the right to declare it non-airworthy, do they not?

This is really no different.

[NovaTTT 1]

I think the PIA TB simply states the obvious: a rig can be opened mid-cycle and a rigger always has a choice of whether to work on a certain rig or not. The main point is probably to clarify when the next AIR is due.

But I believe the language indicates they are saying the rigger who sealed the last AIR should be the one who opens it for mid-cycle work and re-seals it. The comment about being responsible for the airworthiness of the system is where I believe they are casting a pall on the practice of opening another riggers work and re-sealing it.

I could be mistaken, however.

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

[deadwood 0]

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While we're on the subject, does anyone know if a Cypres has ever been found not to operate as designed do solely to being past its' life limit?
My guess is no. But I don't sell AAD's for fun and profit!

One that was past its battery life limit failed to fire and led to a tandem fatality.

As to the unit life limt. I don't know.

He who hesitates shall inherit the earth.

Deadwood
Skydive New Mexico Motorcycle Club, Touring Division

[masterrigger1 2]

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I think the PIA TB simply states the obvious: a rig can be opened mid-cycle and a rigger always has a choice of whether to work on a certain rig or not. The main point is probably to clarify when the next AIR is due.

My point is that we have already concluded that:
1. It is not legal for someone to open a reserve and change the batteries if yhat person is not the one that originally packed the parachute.
That came from Michael Chase, assistant Chief Legal Council, FAA Washington

2. Earlier PIA documents stated the opposite.


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 105]

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It is not legal for someone to open a reserve and change the batteries if that person is not the one that originally packed the parachute.
That came from Michael Chase, assistant Chief Legal Council, FAA Washington

Could you post a copy of his opinion?

Mark