NovaTTT 1 #76 February 1, 2011 Quoteshow me ONE spot in the CFR's that says I have to log work performed on the parachute data card, (not the riggers log book, but the actual parachute data card that goes with the h/c & reserve) As you well know, Ski, CFR 65.131.c says: Each certificated parachute rigger who packs a parachute shall write, on the parachute packing record attached to the parachute, the date and place of the packing and a notation of any defects he finds on inspection. He shall sign that record with his name and the number of his certificate. (emphasis added) It is my practice to include more information than that on the PDC because I think every rigger who looks at that card after me should and ought to be able to understand what rigging has been performed on that equipment. From reading this thread I think you feel the same. But the FAR that regulates this makes it clear that the only records necessary to complete the PDC to FAA standards are the date and place, defects (if any), signature and cert #. Like so much in life, it comes down to theory vs practice."Even in a world where perfection is unattainable, there's still a difference between excellence and mediocrity." Gary73 Quote Share this post Link to post Share on other sites
masterrigger1 2 #77 February 1, 2011 Quote Thanks, I assume in the Ohio TDM your talking about the racer rig. Roger on that! MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
JerryBaumchen 1,048 #78 February 2, 2011 Hi Mark (masterrigger1) QuoteSince you brought it up Intitals or abbreviations are not really legal in FAA documents which you can find in FMIS. You supposed to spell out words. The FAA hates blanks and lack of format. I do not know what letters you get from the FAA but the ones that I have been getting recently from the Aircraft Certification Office ( ACO ) & the Manufacturing Inspection District Office ( MIDO ) sure have a lot of abbreviations with no explanations. Those letters are all here in my files. Heck, they don't even provide a phone number to get back to them. When I worked for the feds ( 30+ yrs ) we considered it simple common courtesy to only use abbreviations after spelling out the wording ( such as: Aircraft Certification Office ( ACO ) ). Just my recent experiences; now back to your regular scheduled programming, JerryBaumchen Quote Share this post Link to post Share on other sites
LouDiamond 1 #79 February 2, 2011 MEL, unless I missed something in the previous posts, I do not see a clear black and white example of a violation of the rules. However, I am seeing what appears to be your interpretation/opinion of what the rules are and how you like to conduct business. I am not saying what you do is wrong or that others are wrong in the way they fill out the data card but it sounds to me like you have beef with the way the PRH is written because it contradicts with your methods and interpretation of the CFR's. According to the written letter, what the others have stated here is indeed in accordance with the CFR's. Of course, if you have another example that clearly(black and white) is in violation of the CFR(s) as you stated, please present it to us here."It's just skydiving..additional drama is not required" Some people dream about flying, I live my dream SKYMONKEY PUBLISHING Quote Share this post Link to post Share on other sites
councilman24 36 #80 February 2, 2011 The undebatable one is how many 8610's are required. PRH says one. Reality is two. One gets you sent back to the FAA inspector. MEL pointed this out earlier. MEL, am I going to have problems with you in Reno?BTW this is NOT a worthy discussion for the time available in Reno. And MEL, AFAIK we don't have your PIA membership application yet.? Should I call your wife? I'm old for my age. Terry Urban D-8631 FAA DPRE Quote Share this post Link to post Share on other sites
mark 102 #81 February 2, 2011 Quote The undebatable one is how many 8610's are required. PRH says one. Reality is two. One gets you sent back to the FAA inspector. That's debatable.The Minneapolis FSDO and the Scottsdale FSDO both require just one 8610-2. They make sure it's correct, make copies, then sign. Mark Quote Share this post Link to post Share on other sites
theonlyski 3 #82 February 2, 2011 I filled out my 8610-2's at the FSDO, he went and dug a couple up and we filled them out in his office. "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 Quote Share this post Link to post Share on other sites
councilman24 36 #83 February 2, 2011 Well it says the inspector will sign 'the' form. But as a DPRE I need two signed forms.I'm old for my age. Terry Urban D-8631 FAA DPRE Quote Share this post Link to post Share on other sites
mjosparky 3 #84 February 2, 2011 QuoteThe H/C is never mentioned in part 65 as having to be recorded. But it is mentioned in part 105: 105.3____ Definitions.For the purposes of this part— Single-harness, dual parachute system: means the combination of a main parachute, approved reserve parachute, and approved single person harness and dual-parachute container. This parachute system may have an operational automatic activation device installed. QuoteBoth the parachute record and the parachute rigger should contain the same info! Not according to the FAA. This is the only reference covering what is required. 65.131 Records. (a) Each certificated parachute rigger shall keep a record of the packing, maintenance, and alteration of parachutes performed or supervised by him. He shall keep in that record, with respect to each parachute worked on, a statement of— (1) Its type and make; (2) Its serial number; (3) The name and address of its owner; (4) The kind and extent of the work performed; (5) The date when and place where the work was performed; and (6) The results of any drop tests made with it. (b) Each person who makes a record under paragraph (a) of this section shall keep it for at least 2 years after the date it is made. (c) Each certificated parachute rigger who packs a parachute shall write, on the parachute packing record attached to the parachute, the date and place of the packing and a notation of any defects he finds on inspection. He shall sign that record with his name and the number of his certificate. QuoteThe H/C's name is usually on the original data card. The manufacturer's Name is on the card The “parachute packing record” is not an official FAA document. The FAA has not even bothered to come up with a standardized format for such a card. You can use a piece of note book paper if you wish. All that is required on the “parachute packing record” is the date and place of the packing, note any defects found and the signature and cert number of the rigger. Even the make, model and ser. Number of the canopy is not required. See Part 65.131 (c) As riggers our personal opinions do not change what is printed by the FAA. SparkyMy idea of a fair fight is clubbing baby seals Quote Share this post Link to post Share on other sites
piisfish 135 #85 February 2, 2011 do you guys have THAT much time on your hands since the 180 days repack cycle ? I am going to vote for a return to 120 days scissors beat paper, paper beat rock, rock beat wingsuit - KarlM Quote Share this post Link to post Share on other sites
masterrigger1 2 #86 February 2, 2011 Quote Since you brought it up Intitals or abbreviations are not really legal in FAA documents which you can find in FMIS. You supposed to spell out words. The FAA hates blanks and lack of format. -------------------------------------------------------------------------------- I do not know what letters you get from the FAA but the ones that I have been getting recently from the Aircraft Certification Office ( ACO ) & the Manufacturing Inspection District Office ( MIDO ) sure have a lot of abbreviations with no explanations. Those letters are all here in my files. Heck, they don't even provide a phone number to get back to them. When I worked for the feds ( 30+ yrs ) we considered it simple common courtesy to only use abbreviations after spelling out the wording ( such as: Aircraft Certification Office ( ACO ) ). Just my recent experiences; now back to your regular scheduled programming, JerryBaumchen Jerry, I guess I did not spell what I intended to spell out. I meant to say that abbreviations and intitals really need to come from an approved list from FSIMS. See attached example. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #87 February 2, 2011 Quote MEL, unless I missed something in the previous posts, I do not see a clear black and white example of a violation of the rules. However, I am seeing what appears to be your interpretation/opinion of what the rules are and how you like to conduct business. I am not saying what you do is wrong or that others are wrong in the way they fill out the data card but it sounds to me like you have beef with the way the PRH is written because it contradicts with your methods and interpretation of the CFR's. According to the written letter, what the others have stated here is indeed in accordance with the CFR's. Lou, This discussion has split between the rigger's logbook and the parachute record/data card. First the Rigger's logbook. 1.It is undisputed that the rigger has to log all work performed in his/her logbook. 2.Airing, Inspecting, and pack or repacking are required actions. 3.With that said, would you not agree that it is in black and white that the rigger has to log all three in his/her logbook..along with any other notable work? I do not think that is a personal opinion BTW. Parachute Record/Data Card The question here is do we mirror/transpose what is in the rigger's logbook in the remarks column. Until now I would have( and did) say absolutely! To be honest what I am seeing/hearing from the FAA is no. Right now I am hearing that the remarks column is for defects..."defects only" being the question. But back to the example in the PRH, 1. If you mirror/transpose what is required in the rigger's logbook, that example would be incorrect. 2.If the rigger is supposed to log "defects only" in the Remarks column, both the PRH and myself are incorrect. The second is starting to look like that is what it is. In either case the PRH example is wrong. BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
riggerpaul 1 #88 February 2, 2011 Okay, we've beaten the horse to death on matters of record keeping and such. Nobody's going to die because of incorrect records. That's not saying that records aren't important. Of course they are for a wide variety of reasons. But I'd like to shift the discussion some, if I may. Mark (MEL), can you point out errors of a practical or physical nature? Is(are) there error(s) where the PRH says to do something in a manner which you feel is wrong, and might result in a failure of a component or system? Please, I don't mean this as a challenge or attack on you. If there are mistakes that might contribute to an injury, I want to know more about them. As I said, nobody is going to get hurt because my records are different from yours. But if there's stuff in there that could hurt somebody, that's a different matter altogether. Thanks! Quote Share this post Link to post Share on other sites
masterrigger1 2 #89 February 2, 2011 Quote The H/C is never mentioned in part 65 as having to be recorded. -------------------------------------------------------------------------------- But it is mentioned in part 105: -------------------------------------------------------------------------------- 105.3____ Definitions.For the purposes of this part— Single-harness, dual parachute system: means the combination of a main parachute, approved reserve parachute, and approved single person harness and dual-parachute container. This parachute system may have an operational automatic activation device installed. -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- In Reply To -------------------------------------------------------------------------------- Both the parachute record and the parachute rigger should contain the same info! -------------------------------------------------------------------------------- Not according to the FAA. This is the only reference covering what is required. We were speaking of records required. There is no verbage that speaks of recording the "parachute system, just "canopy" or "parachute". Let it be known I do think more is better in this case for sure. Quote The “parachute packing record” is not an official FAA document. The FAA has not even bothered to come up with a standardized format for such a card. You can use a piece of note book paper if you wish. No one has ever disputed that IIRC! I made a statement that the orignal data card usually has the manufacture name on it. Quote Even the make, model and ser. Number of the canopy is not required. See Part 65.131 (c) That's going off the deep end.... How is it a record then. Record meaning data specific for that item. It either has to have an identify symbol, mark, or number if this record is not permanently attached to the parachute. c) Each certificated parachute rigger who packs a parachute shall write, on the parachute packing record attached to the parachute, the date and place of the packing and a notation of any defects he finds on inspection. He shall sign that record with his name and the number of his certificate. If you read the sentence through, you will note that the the parachute record is already in existence and you are simply writing the required info onto that record. Quote As riggers our personal opinions do not change what is printed by the FAA. I could not agree more! Cheers, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
LouDiamond 1 #90 February 2, 2011 Quote Lou, This discussion has split between the rigger's logbook and the parachute record/data card. First the Rigger's logbook. 1.It is undisputed that the rigger has to log all work performed in his/her logbook. 2.Airing, Inspecting, and pack or repacking are required actions. 3.With that said, would you not agree that it is in black and white that the rigger has to log all three in his/her logbook..along with any other notable work? I do not think that is a personal opinion BTW. I don't think anyone has contended that. What was brought into question by you and others have asked you to show in black and white, is that AIR has to be written in lieu of I&R to be in compliance. I don't think we need to beat this horse anymore and riggerpaul summed it up about the paperwork. Quote Parachute Record/Data Card The question here is do we mirror/transpose what is in the rigger's logbook in the remarks column. Until now I would have( and did) say absolutely! To be honest what I am seeing/hearing from the FAA is no. Right now I am hearing that the remarks column is for defects..."defects only" being the question. But back to the example in the PRH, 1. If you mirror/transpose what is required in the rigger's logbook, that example would be incorrect. 2.If the rigger is supposed to log "defects only" in the Remarks column, both the PRH and myself are incorrect. The second is starting to look like that is what it is. In either case the PRH example is wrong. BS, MEL As has been mentioned, I am more concerned with knowing about issues that could potentially affect safety in the PHR, if there are any at all. In the beginning of the thread, you made it sound like you had a laundry list of egregious errors in the PRH that constituted it needing to be re-written. I (and I assume others) are interested in hearing what these errors are for the sake of safety. If you have a list of items, please present them all at one time so we can look at and address them as a whole. The ones that people feel are questionable I am sure will cause further discussion."It's just skydiving..additional drama is not required" Some people dream about flying, I live my dream SKYMONKEY PUBLISHING Quote Share this post Link to post Share on other sites
masterrigger1 2 #91 February 2, 2011 Quote don't think anyone has contended that. What was brought into question by you and others have asked you to show in black and white, is that AIR has to be written in lieu of I&R to be in compliance. I don't think we need to beat this horse anymore and riggerpaul summed it up about the paperwork. I have pointed out to you in Black and White that all work must be recorded, not just some work. you're right ...enough already. Quote As has been mentioned, I am more concerned with knowing about issues that could potentially affect safety in the PHR, if there are any at all. In the beginning of the thread, you made it sound like you had a laundry list of egregious errors in the PRH that constituted it needing to be re-written. I (and I assume others) are interested in hearing what these errors are for the sake of safety. If you have a list of items, please present them all at one time so we can look at and address them as a whole. The ones that people feel are questionable I am sure will cause further discussion. Safety was never brought up by myself in this thread. Just mistakes regarding CFRs and etc. And yes it is a long list. Remember this was supposed to be a reference book. Usually reference books hold hardfast facts pertaining whatever the subject matter may be. Two years ago, after the DPRE Recurrent seminar was held, many DPRE's and riggers complained to the FAA about it's material/contents. So much in fact, that one responsible FAA guy actually left Reno early, IIRC. I do not have the time to sit here and hack away at the PRH again. I have done it once for the FAA, just like a few other riggers and DPREs have. I started in the very front of the book,you guys can carry on if you wish.... MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #92 February 2, 2011 Quote Okay, we've beaten the horse to death on matters of record keeping and such. Nobody's going to die because of incorrect records. That's not saying that records aren't important. Of course they are for a wide variety of reasons. But I'd like to shift the discussion some, if I may. Mark (MEL), can you point out errors of a practical or physical nature? Is(are) there error(s) where the PRH says to do something in a manner which you feel is wrong, and might result in a failure of a component or system? Please, I don't mean this as a challenge or attack on you. If there are mistakes that might contribute to an injury, I want to know more about them. As I said, nobody is going to get hurt because my records are different from yours. But if there's stuff in there that could hurt somebody, that's a different matter altogether. Thanks! The only safety issue that I know of is the old deal about relining mains. ...and no, we are not going down that road again! 1. Relining mains has already been classified as a major repair by the FAA (Again) that requires a master rigger certificate or direct supervision under one. 2. It is absolutely amazing that in the PRH, the applicable repairman for relining squares is either a senior or master rigger. Then for relining a Round main (and it is even more simplistic) it calls for a Master rigger only! Basically if you use this book as a reference for relining a square canopy, and you have a senior rigger's certificate without a master rigger's supervision, you will be in violation of your privileges. This one is hard fast. The FAA has look at it repeatedly. Although they were trying to get this justified (the PRH recommendations on applicable repairmen) by trying to push it through in the new purposed AC-105-2C. The book is riddled with personal opinions if you care to look for them. The end! MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
mjosparky 3 #93 February 2, 2011 QuoteJerry, I guess I did not spell what I intended to spell out. I meant to say that abbreviations and intitals really need to come from an approved list from FSIMS. See attached example. MEL That is a list of Acronyms and Abbreviations to be used by an Inspector when using a specific handbook, GENERAL INSPECTOR GUIDANCE AND INFORMATION. It makes no mention of rigging, parachutes or record keeping by riggers. Is there is such a list for use when dealing with Part 65? I have never seen it or even heard of it. Since it is not widely distributed to riggers in the field it stands to reason that they can’t be required to use it. In any paper work that I generate I use initials and abbreviations that follow the rules of proper grammar. SparkyMy idea of a fair fight is clubbing baby seals Quote Share this post Link to post Share on other sites
mjosparky 3 #94 February 2, 2011 QuoteWe were speaking of records required. 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. To put these things in your “Test Plan” and fail a candidate for not complying with what amounts to your opinion of what is needed is just wrong. That’s where confusing starts and standardization gets lost. SparkyMy idea of a fair fight is clubbing baby seals Quote Share this post Link to post Share on other sites
mark 102 #95 February 2, 2011 QuoteThe only safety issue that I know of is the old deal about relining mains. ...and no, we are not going down that road again! 1. Relining mains has already been classified as a major repair by the FAA (Again) that requires a master rigger certificate or direct supervision under one. 2. It is absolutely amazing that in the PRH, the applicable repairman for relining squares is either a senior or master rigger. Then for relining a Round main (and it is even more simplistic) it calls for a Master rigger only! Basically if you use this book as a reference for relining a square canopy, and you have a senior rigger's certificate without a master rigger's supervision, you will be in violation of your privileges. This one is hard fast. The FAA has look at it repeatedly. Looks like we're going down that road again anyway. 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. In the most common industry reference, Poynter's Parachute Manual, there are a number of references to line repairs and replacements, and all say a senior rigger certificate is sufficient for line work on a main parachute. That has been the case since the original Parachute Manual was published in 1971. 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. Mark Quote Share this post Link to post Share on other sites
JerryBaumchen 1,048 #96 February 2, 2011 Hi Mark (masterrigger1), Quote I guess I did not spell what I intended to spell out. I am as guilty of this as anyone. Quote See attached example. Interestingly, one that the FAA has been using a lot recently is not even on that listing. There's your tax money at work. JerryBaumchen PS) You wouldn't have the tube that goes from the oil reservoir to the oil pump on a Pfaff 463 in stock? I need one. If you have one, drop me an email or pm. Thanks. Quote Share this post Link to post Share on other sites
riggerpaul 1 #97 February 2, 2011 QuoteQuoteThe only safety issue that I know of is the old deal about relining mains. ...and no, we are not going down that road again! 1. Relining mains has already been classified as a major repair by the FAA (Again) that requires a master rigger certificate or direct supervision under one. 2. It is absolutely amazing that in the PRH, the applicable repairman for relining squares is either a senior or master rigger. Then for relining a Round main (and it is even more simplistic) it calls for a Master rigger only! Basically if you use this book as a reference for relining a square canopy, and you have a senior rigger's certificate without a master rigger's supervision, you will be in violation of your privileges. This one is hard fast. The FAA has look at it repeatedly. Looks like we're going down that road again anyway. 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. In the most common industry reference, Poynter's Parachute Manual, there are a number of references to line repairs and replacements, and all say a senior rigger certificate is sufficient for line work on a main parachute. That has been the case since the original Parachute Manual was published in 1971. 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. Mark You didn't even mention that the draft of AC-105 that is kicking around includes language saying a senior can replace a line on a main. I know that MEL argues that such a statement is wrong, but the very presence seems to indicate that there is a shift possible on this particular point. MEL, can you stick to the safety issues, please? Is the information about the techniques for a main reline wrong to the extent that following it will likely result in an unsafe parachute? That would be a safety issue. Worrying about who does the work, given that the work is being done properly, is a regulatory issue. Is that the only safety issue you have? Thanks! Quote Share this post Link to post Share on other sites
masterrigger1 2 #98 February 2, 2011 Quote 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! Quote To put these things in your “Test Plan” and fail a candidate for not complying with what amounts to your opinion of what is needed is just wrong. That’s where confusing starts and standardization gets lost. My test plane is subitted and reviewed by the FAA before use. So they must agree with it. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
theonlyski 3 #99 February 2, 2011 QuoteQuote 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."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 Quote Share this post Link to post Share on other sites
mark 102 #100 February 2, 2011 QuoteMy test plan is submitted to and reviewed by the FAA before use. So they must agree with it. MEL 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. Mark Quote Share this post Link to post Share on other sites
