Parachute Rigger Handbook

[pchapman 261]

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My test plan is submitted and reviewed by the FAA before use. So they must agree with it.
MEL

I guess the same could be said about the Parachute Rigger Handbook.
Back to the discussion...

[masterrigger1 2]

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The FAA has never classified relining mains as a major repair, except possibly in AC 105-2C, which is not a regulation and which is open to interpretation.

Not possibly.
It does state in AC-105-2C that a line repair is a major repair.

Also in the preamble of the latest correction of 65.111, it states that main canopies also require appropriate certificates to do the work desired.

And for the ones that do not know, only master riggers are allowed to do major repairs (or someone under their supervision.

You know this and it is also the reason the new purposed AC is worded as it is.....

c. Major or Minor Repair Determination. When there is a question about whether a
particular repair is major or minor, the manufacturer’s instructions, supplemented by The
Parachute Manual and The Parachute Rigger Handbook (see subparagraph 13e), may be used as
guides.
(1) If the procedure calls for a master rigger, it should be considered a major repair. If the
procedure allows for a senior rigger, it should be considered a minor repair. The same kind of
repair may be classed as major or minor depending on size or proximity to key structural
components. For example, a basic patch may be a minor repair if it is small and away from
seams, but may be a major repair if it is large or adjacent to a seam.


You say that AC-105-2C is not regulatory, but it sure seems to me you are trying to make the purposed new one regulatory here.

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The FAA may have looked at this issue repeatedly, but until they produce something in writing, we can have no confidence in what someone says they purportedly think.

That goes both ways....
I have to think there is more in writting on my version than your version, but there I go, thinking again.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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I guess the same could be said about the Parachute Rigger Handbook.

I guess you could, but they admitted to basically not reviewing it as needed.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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Your test plan is submitted to and approved by an inspector at your local FSDO, whose jurisdiction does not extend beyond the geographical limits of the district, and who may or may not be familiar with the state of the art. It does not represent the position of the FAA as a whole, and other FSDOs may have different standards.

They are still the FAA.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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Yes we were. And some of what you say is required is not according to CFR's. While they may be a good idea they are not required by the FAA.

--------------------------------------------------------------------------------

Again,
I show you airing is required by the regs...period. It is in black and white.

You are required to log work done. What part of that do you not get!

--------------------------------------------------------------------------------


The part that you say its required to write it on the PDC.

Son,
You need to catch up on your reading.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mjosparky 3]

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I show you airing is required by the regs...period. It is in black and white.

You are required to log work done. What part of that do you not get!

If you notice I didn’t mention airing the canopy. But it stands to reason that if the canopy was not wet it doesn’t need to be dried.
What I don’t get is why you can’t or won’t show in black and white all the other things you claim must be done. Things related to record keeping. On the “parachute packing record” all that is required by CFR’s is “the date and place of the packing and a notation of any defects he finds on inspection.” The rigger then must sign it and list his cert number. Listing the work preformed in remarks is not required. And that has been posted in black and white several times.

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My test plane is subitted and reviewed by the FAA before use. So they must agree with it.

MEL

Failing a candidate on items that are not backed up by the CFR’s is still wrong. They should be tested on what the FAA requires not what you think is right. How can there be any consistency in the program if everyone is making up their own rules?

Sparky

My idea of a fair fight is clubbing baby seals

[LouDiamond 1]

MEL, I (and I am sure others) have come to the conclusion that you are simply stating your opinion/interpretation in these matters over and over again. You have yet to present any evidence that the PRH is in clear violation of the CFRs or that it contains information that is erroneous enough to pose a safety concern.

The PRH may possibly need an update, which is a valid concern as things can and do change over time when any book is published. However, I am unaware of anything in it (PRH)that if followed would put the user of that information in violation of a CFR(s) or create an unsafe situation. So, again, if you are aware of any issues that fall into the categories I just described, please list them in their entirety. I am not speaking about nit picking issues where there is no clear evidence (like the AIR topic) to support your claims but rather cut and dry wrong/unsafe where it can be seen and reviewed by all.

I am giving you the benefit of the doubt here and asking to hear what these issues are because I'd like to know what they are in the hopes of seeing the PRH corrected if it is indeed wrong in some places. However, so far, all you have posted here can be chalked up to your opinion/interpretation, which seems to be contradictory to what everyone else in the field agrees is the correct and standard procedure IAW the CFRs. So again, please list the issues you mentioned exist in the PRH.

"It's just skydiving..additional drama is not required"
Some people dream about flying, I live my dream
SKYMONKEY PUBLISHING

[masterrigger1 2]

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If you notice I didn’t mention airing the canopy. But it stands to reason that if the canopy was not wet it doesn’t need to be dried.

But it needs to be aired according to the Regulations, It is there in black and white.

Quote

On the “parachute packing record” all that is required by CFR’s is “the date and place of the packing and a notation of any defects he finds on inspection.” The rigger then must sign it and list his cert number. Listing the work preformed in remarks is not required. And that has been posted in black and white several times.

Move away from the PDC and focus just on the riggers logbook.
There all work done must be recorded.

I found out today from the FAA that all that needs to be on the PDC is what is listed in 65,131 (C)

The reason why is that 65.131 (a)1-6 and (b) has been complied with. (i never looked at it like that)

So in other words,on the PDC, if no defects are found, the remarks column is to be left blank,

All other entries (work performed) need to be in the riggers logbook, This does require ALL work or required actions performed.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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MEL, I (and I am sure others) have come to the conclusion that you are simply stating your opinion/interpretation in these matters over and over again. You have yet to present any evidence that the PRH is in clear violation of the CFRs or that it contains information that is erroneous enough to pose a safety concern.

I never brought up a safety concern until late in this discussion.

If you do not see the evidence, you never will.
The whole point to the begining of this thread was that I&R is not a complete required documentation.

I have shown in the FARs that airing a parachute is a required action.(black and white)

I have also shown that the rigger is required to document all work and services peformed.(black and white)

I thought ( with error) that the PDC was to reflect the same information that is required in the rigger's logbook.

As in the previous post the PDC is only to reflect defects in the remark column as work performed should have already been correctly recorded in the riggers logbook. (black and white)
In other words the PDC does not have to have the info but it has to be logged in the rigger.s logbook.

If you feel that the above is personal opinion, I do not know what to say to you.
It is spelled out right there in Part 65.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[LouDiamond 1]

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I never brought up a safety concern until late in this discussion.

If you do not see the evidence, you never will.

I and others have asked you MULTIPLE times to list these issues that you claim exist. I've looked in my copy, I don't see anything that I can discern that is a blatant CFR violation or that could create a safety issue, so please enlighten everyone. I am about ready to throw the BS flag at your claim that these violations exist. Cut the secret squirrel shit and lay down your cards and come clean with this list of yours, if it even exists.

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The whole point to the begining of this thread was that I&R is not a complete required documentation.

I have shown in the FARs that airing a parachute is a required action.(black and white)

I don't think anyone here has disputed that, airing as well as a laundry list of other shit has to be done but you have not shown where it says that AIR has to be written on the PDC as you claimed and that I&R by itself is incorrect( you actually acknowledge your error in your statement below so this horse is thoroughly beaten to death). Which brings us to the next topic, the other "things" you claim are wrong with the PRH, please elaborate.

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I have also shown that the rigger is required to document all work and services peformed.(black and white)

I thought ( with error) that the PDC was to reflect the same information that is required in the rigger's logbook.

As in the previous post the PDC is only to reflect defects in the remark column as work performed should have already been correctly recorded in the riggers logbook. (black and white)
In other words the PDC does not have to have the info but it has to be logged in the rigger.s logbook.

If you feel that the above is personal opinion, I do not know what to say to you.
It is spelled out right there in Part 65.

MEL

Again, I don't recall anyone disputing what is supposed to be logged in the Riggers logbook, it was your insistence that I&R on the PDC was incorrect. You have since conceded that you were wrong on this point but you still have not provided evidence of the other errors that you claim are in the PRH exist. I am still waiting to hear what else we need to be concerned about now that we have moved past the PDC requirements. I'm not trying to bust your balls here but I am beginning to think this list of CFR violations that you claim are in the PRH is a bunch of BS. Please prove me wrong and provide the evidence to support your claim.

"It's just skydiving..additional drama is not required"
Some people dream about flying, I live my dream
SKYMONKEY PUBLISHING

[mjosparky 3]

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Quote

I guess the same could be said about the Parachute Rigger Handbook.

I guess you could, but they admitted to basically not reviewing it as needed.

MEL

And I guess you could say the same thing about your test plan.

No one has disputed that a record of all work done is to be recorded in the Riggers Log Book. The point of contention is your insistence that the same items had to be listed on the PPR. When asked to supply a link to the CFR that required this you can back with a smart ass remark and still would not answer the question.

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Again,

I show you airing is required by the regs...period. It is in black and white. You are required to log work done. What part of that do you not get!

This one is particularly condescending

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Son,
You need to catch up on your reading.

These remarks bring nothing to the discussion.

Quote

Also in the preamble of the latest correction of 65.111, it states that main canopies also require appropriate certificates to do the work desired.

It says to work on canopies you must have some type of certificate. Without defining what the “work desired” is this means nothing.

As Scott has stated you tend to take your own opinion/interpretation and sell it as fact. When the two conflict all you accomplish is to muddy the water making any useful exchange impossible.

Sparky

My idea of a fair fight is clubbing baby seals

[parachutist 1]

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Move away from the PDC and focus just on the riggers logbook.
There all work done must be recorded.

The problem here: I doubt many riggers are hanging all nylon reserves in a dry warm environment for an extended period of time to air them out. So it seems if everyone wrote "Air" in their log books it'd be much like pencil packing: a rigger stating that he's done something which he actually hasn't.

Chris

[riggerpaul 1]

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And for the ones that do not know, only master riggers are allowed to do major repairs (or someone under their supervision.

You know this and it is also the reason the new purposed AC is worded as it is.....

c. Major or Minor Repair Determination. When there is a question about whether a
particular repair is major or minor, the manufacturer’s instructions, supplemented by The
Parachute Manual and The Parachute Rigger Handbook (see subparagraph 13e), may be used as
guides.
(1) If the procedure calls for a master rigger, it should be considered a major repair. If the
procedure allows for a senior rigger, it should be considered a minor repair. The same kind of
repair may be classed as major or minor depending on size or proximity to key structural
components. For example, a basic patch may be a minor repair if it is small and away from
seams, but may be a major repair if it is large or adjacent to a seam.


You say that AC-105-2C is not regulatory, but it sure seems to me you are trying to make the purposed new one regulatory here.

MEL, why didn't you include the next paragraph in the material quoted from DRAFT AC-105-2D?

Here's the paragraph

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(2) Because of the absence of airworthiness standards for unapproved components, the
same kind of repair may be classed as major or minor depending on whether it is done to an
approved or unapproved component. For example, the replacement of a suspension line on a
reserve canopy is a major repair, while replacement of a suspension line on a main canopy is
generally considered a minor repair, even if the identical technique is required for both
replacements.

I know you don't like it much, but this paragraph is pretty clear that mains and reserves have different definitions for major and minor repairs.

Don't just pick the paragraphs you like when you quote.

[Mailed_Fist 0]

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Not mine!

This manual has several issues and a contract has been inititated for it's immediate replacement.

The "issues" range from personal opinion of pratices to lack of knowledge of the CFRs(FARs) in a few areas.

...but it sure has some pretty pictures in it!

I am a rigger making observations on this thread and this is not a PA. These points are important for all riggers to consider and understand, especially since it concerns one of the basic reference materials of the trade.

MEL, this was your first of many contributions to this thread and has nothing to do with purchasing a hardcopy of the PRH - the OPs question. Neither does it clarify anything.

You've put yourself out there by your own choice and now as a DPRE and master rigger you should back up your comments.

The appearance is that since that first post you've been put over the barrel and after having your ass spanked, you've had it handed to you on a silver platter. That doesn't look good, considering you are a master rigger and DPRE.

Why muddy the waters further? We all make mistakes - even master riggers and DPREs. It's easier to just admit them up front and move on than it is to defend an indefensible position.

The FARs do not support your contention that the record attached to the parachute must contain anything other than what is contained in 65.131. Further, it is violation of moral turpitude that you test and fail candidates on information that is known to you to be false. And you defend that? Shame on you.

I don't understand why you didn't (and don't) just say, "I was wrong. I'll correct that. Let's move on."

Then we can move on to the specific "several issues" in the PRH which you mentioned. There can then be discussion.

You identified the issues as:

(1) Personal Opinion of Practices

Please identify and explain.

But I don't see where you have ground upon which to stand. You are, based on opinion, knowingly violating your duties as DPRE on one count we know of. Please explain how this differs from opinion which may be contained in the PRH.

(2) Lack of Knowledge of the CFRs

Please identify and explain.

But I don't see where you have ground upon which to stand. You are a master rigger and DPRE and you are not familiar with 65.131 and rigger record keeping. That's Rigging 101 and that you don't understand it does not inspire confidence or trust.

(3) Range

Please identify and explain what is contained within said range.



These points were all brought into this discussion by you, MEL. I observe you have been defensive, evasive, condescending and strangely arrogant within this thread.

That strikes me as interesting, as the point you've shown the most arrogance about is the Rigging 101 record keeping topic that you didn't even understand!

So I hope you are not going to resort to obfuscation and redirection (misdirection?) and will just come out and stand behind your words. The words you made the choice to put out here.

Other posters have asked you to explain and clarify. As a master rigger and DPRE I think it is your duty to support the comments you make to other riggers in a public forum.

I am not defending the PRH, and I don't have a horse in this race other than having an interest, as a rigger, that the reference materials are accurate and that FAA appointed Rigger Examiners know what they are doing, what they should be doing, what their privileges and duties are, and that they effect those duties with the knowlege, respect and humility said appointment demands.

Mailed Fist

[masterrigger1 2]

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I and others have asked you MULTIPLE times to list these issues that you claim exist. I've looked in my copy, I don't see anything that I can discern that is a blatant CFR violation or that could create a safety issue, so please enlighten everyone.

Scott,
I f you look and my very first post

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Not mine!

This manual has several issues and a contract has been inititated for it's immediate replacement.

The "issues" range from personal opinion of pratices to lack of knowledge of the CFRs(FARs) in a few areas.

...but it sure has some pretty pictures in it!

I do not understand were you keep coming up with I said something about safety related issues other than the relining of mains by Senior riggers.


I simply opened the book once you requested some examples and started in the front.
The first example was about the differences in the needed 8610-2s.
The PRH states just one and two is required.
See below:

h. Two originals of FAA Form 8610-2 shall be
received from the applicant before testing begins. FAA
Form 8610-2 shall be completed in accordance with
Appendix 2, Instructions for Completing FAA
Form 8610-2, Airman Certificate and/or Rating
Application, found in this order. The DPRE or inspector
should provide FAA Form 8610-2, and give detailed
instructions for completing it correctly. (Inspector or
DPRE shall copy appendix 2 of this order to provide to
the applicant until FAA Form 8610-2 is revised with
written instructions attached.) The applicant shall be
advised to read and remove the supplemental information
(PRIVACY ACT) attached to FAA Form 8610-2. (See
appendix 2, figure 2-1.)
NOTE: All signatures shall be original, in dark ink,
with the name printed in dark ink or type written
below or next to the signature.

I think this covers the 8610-2 issue....



The next issue was the PDC example.
I stated it was incorrect.

I stand by the same statement, but for a different reason.

I stated that is was incorrect because the Air was omitted in the remarks column when in fact nothing except defects is supposedly needed there. "Inspect and Repack" are not defects, therefore incorrect as we see it now.

The truth is now known that the remarks column is reserved for defects found during the operation of reacking. This proves me wrong about the PDC, but just the PDC.

"Defects only" is a question that I am presenting to legal.
In other words can we (as we always have done) include what is recorded in the rigger's logbook in the remarks column.


At the same time if If AIR was omitted int the PDC , it more than likely is omitted from the rigger's logbook as well, as most riggers transpose exactly what is written in their logbooks to reflect the same work performed.

The last part would be not in accordance with the regulations as a rigger has to log all work performed in his or her logbook. ...and airing is a required action.

I think the above has been presented as regulation, not personal opinion.

It all comes down to three things:
1. All actions performed have to be logged in your logbook. 65.131 (a) 1-6
2. "Air "is spelled out in the regulations as being a required action. 65.129(c)
3. The PDC card just needs defects listed in the remarks column to be legal. It does not require Air inspect , and repack in that column, much less the more incorrect version of I&R written there as shown in the PRH. 65.131 (c)


So far everything is covered with documentation as per the CFRs.

Dead horse buried here!

Next relining main as a senior rigger.

65.125 Certificates: Privileges.
top
(a) A certificated senior parachute rigger may—

(1) Pack or maintain (except for major repair) any type of parachute for which he is rated; and


Replacing a suspension line is considered a major repair in AC-105-2C paragraph 12.

Major repair is defined as one that improperly done, might appreciably affect weight and balance and/or effect airworthiness.
See attached definitions- paragraph O.

Also to solidify the requirement that main canopies need an appropriate certificate (appropriate meaning as required for the task) to work on them, see attached Part 65 Interp.

The old argument was that mains were not regulated nor controlled. This Preamble in Part 65 Interp removes that old, incorrect theory.


I think there is plenty here to dispel my "opinion" as being documented fact.

I am done with that also.

Dead horse #2 buried here.


The next thing was about the required 40 foot table.
It is required.
65.127 Facilities and equipment.
top
No certificated parachute rigger may exercise the privileges of his certificate unless he has at least the following facilities and equipment available to him:

(a) A smooth top table at least three feet wide by 40 feet long.

The PRH states that can pack elsewhere which is a direct violation of the listed CFR.
The statement in the PRH is merely personal opinion and also not constant with the CFR that states the rigger "shall have" not "should have".

...again not my personal opinion, just fact.

I think you will find that this is enough evidence to support my claims thus far.

I have neither the time or desire to sit here and try to convince everyone what several other riggers have already discovered as multiple errors in the PRH.

There is always going to be the nah-sayers and people that will argue because they simply were taught differently, especially ones that were taught by the guys that wrote the book.

Hopefully the new one will be more correct!

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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MEL, why didn't you include the next paragraph in the material quoted from DRAFT AC-105-2D?

I put in just enough to show that the Ac was trying to add to the regulations.

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I know you don't like it much, but this paragraph is pretty clear that mains and reserves have different definitions for major and minor repairs.

Legal has it in their hands to see about removing it.
It is still in draft status.( not active)

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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It says to work on canopies you must have some type of certificate. Without defining what the “work desired” is this means nothing.

I think it is defined.
Major repairs = masterrigger
Minor repairs = senior or master rigger

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As Scott has stated you tend to take your own opinion/interpretation and sell it as fact. When the two conflict all you accomplish is to muddy the water making any useful exchange impossible.

Maybe.
But I usually do my homework.
In this case I was wrong about the PDC, but right about having to include Air in the logbook.


Do we need to do another 7 year tenture like we did with the main canopy issue?

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[NovaTTT 1]

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I stated that is was incorrect because the Air was omitted in the remarks column when in fact nothing except defects is supposedly needed there. "Inspect and Repack" are not defects, therefore incorrect as we see it now.

The truth is now known that the remarks column is reserved for defects found during the operation of reacking. This proves me wrong about the PDC, but just the PDC.

I don't think the space is "reserved", but I do think defects is the only info *required* to be logged there. There's nothing in the FARs that tell us what we should not put there.

As I mentioned earlier, I like to fill in the blank so subsequent riggers will know what rigging has been performed on the equipment. I haven't seen anything to make me think this is wrong.

.02

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

[riggerrob 558]

Is a meeting of FAA DPREs scheduled for the PIA SYmposium?
If so, good!
That is where this debate should be settled.

Rob Warner
FAA Master Rigger
CSPA Rigger Examiner

[mark 102]

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Next relining main as a senior rigger.

65.125 Certificates: Privileges.
top
(a) A certificated senior parachute rigger may—

(1) Pack or maintain (except for major repair) any type of parachute for which he is rated; and

Replacing a suspension line is considered a major repair in AC-105-2C paragraph 12.

Major repair is defined as one that improperly done, might appreciably affect weight and balance and/or effect airworthiness.
See attached definitions- paragraph O.

Also to solidify the requirement that main canopies need an appropriate certificate (appropriate meaning as required for the task) to work on them, see attached Part 65 Interp.

The old argument was that mains were not regulated nor controlled. This Preamble in Part 65 Interp removes that old, incorrect theory.

I think there is plenty here to dispel my "opinion" as being documented fact.

The only place that replacing any suspension line is considered a major repair is in AC 105-2C. The language in the draft AC 105-2D is in line with 40 years of practice following Poynter's Parachute Manual.

There are no airworthiness standards for main parachutes. It follows that a main parachute cannot be made unairworthy. There is no such thing as a major repair (as defined above) to a main parachute, and any repairs may be made by a senior rigger. The preamble to the Part 65 revision issued last year does not change that.

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The next thing was about the required 40 foot table.
It is required.
65.127 Facilities and equipment.
No certificated parachute rigger may exercise the privileges of his certificate unless he has at least the following facilities and equipment available to him:

(a) A smooth top table at least three feet wide by 40 feet long.

The PRH states that can pack elsewhere which is a direct violation of the listed CFR.
The statement in the PRH is merely personal opinion and also not constant with the CFR that states the rigger "shall have" not "should have".

The regulation does not require the table to be used for anything, just that it be available. No regulations require parachutes of any kind to be packed on a table.

...again not my personal opinion, just fact.

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There are always going to be the nay-sayers and people that will argue because they simply were taught differently, especially ones that were taught by the guys that wrote the book.

I'm not the guy who wrote the book, and I wasn't taught by him. I just run his rigging courses. I would be remiss if I didn't teach senior riggers how to replace lines or do complex patches. And I would be doing them a disservice if I didn't insist they demonstrate the ability to pack the round canopies their certificates will entitle them to pack.

Mark

[masterrigger1 2]

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The appearance is that since that first post you've been put over the barrel and after having your ass spanked, you've had it handed to you on a silver platter. That doesn't look good, considering you are a master rigger and DPRE.

I do not see it that way, nor do several other people monitoring the thread.

Quote

Why muddy the waters further? We all make mistakes - even master riggers and DPREs. It's easier to just admit them up front and move on than it is to defend an indefensible position.

The FARs do not support your contention that the record attached to the parachute must contain anything other than what is contained in 65.131.

You need to go back and re-read the posts were I said that the PDC was an error on my part.

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Further, it is violation of moral turpitude that you test and fail candidates on information that is known to you to be false. And you defend that? Shame on you.

Usually an applicant writes in his logbook the exact information that he would write on the data card.
Therefore if AIR is missing there, proper recording is not adhered to.
Also if they write I&R when if fact they assembled the parachute, failure is also justified.

See attached.

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(1) Personal Opinion of Practices

Please identify and explain.

But I don't see where you have ground upon which to stand. You are, based on opinion, knowingly violating your duties as DPRE on one count we know of. Please explain how this differs from opinion which may be contained in the PRH.

Stating that I have violated my duty as a DPRE is very offensive ,unjust, and basically defamation of character as I see it.

The test standards provide guidance to actually test in that area BTW.

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But I don't see where you have ground upon which to stand. You are a master rigger and DPRE and you are not familiar with 65.131 and rigger record keeping. That's Rigging 101 and that you don't understand it does not inspire confidence or trust.

If you have not noticed, everyone has seems to missed the boat with regards to the remarks column.

....even the example in the PRH and it has a FAA stamp on it.

To recap, the remarks column is supposed to have defects listed there.

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These points were all brought into this discussion by you, MEL. I observe you have been defensive, evasive, condescending and strangely arrogant within this thread.

Sorry that you see it that way>

I have been dealing with issues with this book for three years or better.

In case you did not know, Several DPRE's, Master riggers and senior riggers had a meeting here in my shop, with OKC last March regarding the issues with the PRH.

Quote

Other posters have asked you to explain and clarify. As a master rigger and DPRE I think it is your duty to support the comments you make to other riggers in a public forum.

I have presented some of them. I do not have enough time to do them all.

I think the fact that the FAA is replacing the book says enough.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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There are no airworthiness standards for main parachutes. It follows that a main parachute cannot be made unairworthy. There is no such thing as a major repair (as defined above) to a main parachute, and any repairs may be made by a senior rigger. The preamble to the Part 65 revision issued last year does not change that.

So you are saying airworthy only applies to a reserve parachute?
What document supports what you contend in black and white?

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The regulation does not require the table to be used for anything, just that it be available. No regulations require parachutes of any kind to be packed on a table.

...again not my personal opinion, just fact.

The facilities are required also.

I guess that I just need to have them also and pack outdoors on the grass.

Also see attached.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 102]

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In case you did not know, Several DPRE's, Master riggers and senior riggers had a meeting here in my shop, with OKC last March regarding the issues with the PRH.

Umm. Really? I thought your meeting was with AFS-640 and had to do with problems with the written test. Why didn't you invite the folks from AFS-630 who are responsible for the PRH? If you wanted to talk about the PRH, your meeting would have been much more productive that way.

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I think the fact that the FAA is replacing the book says enough.

The PRH is only of many such handbooks published by the FAA. The FAA tries to update its handbooks every five years, budget permitting. Because the PRH was published in 2005, it is due for revision based on the passage of time. Saying that the FAA is "replacing" the PRH is not saying much at all.

Mark

[mark 102]

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So you are saying airworthy only applies to a reserve parachute?

I am saying there are no published airworthiness standards for main parachutes.

Mark

[masterrigger1 2]

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Umm. Really? I thought your meeting was with AFS-640 and had to do with problems with the written test. Why didn't you invite the folks from AFS-630 who are responsible for the PRH? If you wanted to talk about the PRH, your meeting would have been much more productive that way.

The written test had issues because the PRH was used for some of the test questions as their basis.

AFS-630 was here BTW.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com