Service Bulletins and Equipment Bannings

[tetra316 0]

I got into an interesting discussion with someone that none of these bans are legally enforcable. In order to be legally binding it has to come from the FAA. Meaning all gear that is initially approved for use by the FAA is legal. That no service bulletins issued after that fact, UNLESS also issued by the FAA, are legally mandated. The service bulletins are mere advice and would not be upheld in court since the FAA does not recognize them by also approving the bulletins. Some bulletins have been issued by the FAA but most come directly from the manufacturer. The manufacturer has no legal authority to limit what people do with their products. They can issue disclaimers but that's it. The FAA is the legal body in this sport.

So what this means, is that there are no legal grounds to enforce service bulletins or manufacturer recommendations, unless also backed by the FAA. You cannot be held legally accountable for not following such, unless the FAA has stated you have to. The argument was that people do follow them as a CYA. But sometimes there comes a point where the cost of following such bulletins/recommendations outweighs the CYA factor. Then they choose not to adhere. Also, sometimes the bannings and recommendations seem to be knee jerk reactions issued without also issuing all the data that brought about the banning.

Sorry for my lack of technical knowledge of the process but you get the picture.

Personally, I'm not sure I buy into that argument since I tend to think that "standard industry practices", whether or not legally enforceable, would take precedence in court. Others think that the courts would strictly follow the letter of the law and ignore "standard industry practice". Either way it was a thought provoking discussion.

[tetra316 0]

As to repacking a rig with a manufacturer banned piece of equipment, the argument was that is legal. The FAA approved each piece of equipment at that date of approval for it's intended use. That approval is valid no matter what the manufacturer decides after that date. If the manufacturer wishes to ban anything or modify anything then they need to submit such to the FAA and it needs to be approved by the FAA in order to be legally enforceable. After all, the riggers ticket is issued by the FAA, not the manufacturer.

Again not sure I buy into this but I do see the train of thought.

[sundevil777 98]

Because riggers have to follow mfg instructions, I think the argument is wrong. That general requirement has a long reach, I would think. As some have suggested, until a rig needs to be repacked, a person can get by keeping an Argus in their rig until a repack, or until a DZO decides to enforce the mfg recommendation.

People are sick and tired of being told that ordinary and decent people are fed up in this country with being sick and tired. I’m certainly not, and I’m sick and tired of being told that I am

[NovaTTT 2]

The fallback is FAR 65.129.e:

(No certificated parachute rigger may) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute;

Does that mean the written instructions in the manual? Does that mean SBs that are issued by manufacturers? Does that mean what the mfgr's house rigger says?

I suppose in the end that's up for a court to decide. As for me, I'm not willing to be a test-case in a court of law.

But more importantly, I'm not willing to put someone's life at risk. Were I to knowingly pack a banned piece of equipment thinking it's technically legal and someone were to die because of that piece of equipment the legality of the matter would be the least weight on my conscience.

I'm comfortable with the manufacturers deciding what is OK and what is not with their gear.

FWIW.

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

[GLIDEANGLE 1]

In the USA.... the following applies to riggers:

FAR 65.129 — Performance standards.
No certificated parachute rigger may—

(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute;

So... YES the H/C manufacturer can definitely decide what can be packed with their gear.

The choices we make have consequences, for us & for others!

[Slurp56 0]

Hey Tara,

As I understand it, what you are reffering to is an Airworthiness Directive (AD). AD's are issued by the FAA and are mandatory. Service Bulletins (SB) are issued by the manufacturer and are considered recommendations and are not mandatory. The above applies to most sectors of aviation, and then you have subpart F, Parachute Riggers.

As others have contributed, CFR 14 Part 65.129(e) says pretty plainly that parachute riggers must not deviate from the procedures approved by the administrator (FAA) or Manufacturer. It's a round-a-bout way to make parachute manufacturers service bulletins mandatory.

You'd be correct in almost every other corner of avaiation as far as the FAA is concerned.

________________________________________
I have proof-read this post 500 times, but I guarantee you'll still manage to find a flaw.

[RiggerLee 61]

Sorry,no. It doesn't work that way and honestly neather the FAA nor you want it to. The FAA is a huge lumbering buricratic giant. It can't get any thing done to save it's life and it doesn't want to deal with any of this any ways.

What he's refering to is AD's which do come from the FAA. They are really to lazy to do this for skydiving. I can't even recall the last one maybe capewell. Don't hold your breath on them doing another.

SB are from manufactorers. They are binding in the sence that the FAR's require you to maintaine the equipment per there instruction hence the refrence to the FAR violation. The Manufactorer has full athority to do this up to the point of saying that instalation interfears with it's operation and voids the TSO at which point no it is not airworthy and signing it off is a violation, or alllowing it to fly in your plane is a vilation, and they could even try to vilate you for jumping it, up to $1000 per incedent. Bland tryed to explane that to me how that worked once but I don't recall the exact argument. Example, he made noises about threatening to do that on the stall incedent.

So no. They are not airworthy.

Lee

Lee
[email protected]
www.velocitysportswear.com

[firemedic 7]

Quote

As to repacking a rig with a manufacturer banned piece of equipment, the argument was that is legal. The FAA approved each piece of equipment at that date of approval for it's intended use. That approval is valid no matter what the manufacturer decides after that date. If the manufacturer wishes to ban anything or modify anything then they need to submit such to the FAA and it needs to be approved by the FAA in order to be legally enforceable. After all, the riggers ticket is issued by the FAA, not the manufacturer.

Again not sure I buy into this but I do see the train of thought.

Read this excerpt from FAA Document AC 105-2C.
I think this issue is covered here. The FAA is saying that an AAD installation must be approved by the manufacturer. I believe this specifically addressed the installation configuration such as pouch location, cutter location, control unit location, etc. However, the area here is sufficiently gray, to me at least, that it may include the device itself.

Paragraph 4. e. (2)

(2) –Automatic Activation Devices. A jumper may have a tendency to feel more at ease if equipped with an automatic activation device (AAD).
However, experience shows that such devices may not be completely reliable and Should be used only as a backup to proper training and procedures.
Skydivers who use an AAD on their reserve/auxiliary parachute should ensure that the installation of such a device has been approved by the parachute manufacturer
or the FAA (see paragraph 8).
The FAA does not approve AAD's.
They do approve the installation which is submitted with the manufacturer's TSO paperwork. The manufacturer's instructions for installation should be followed.
The installation of an AAD to a TSO or military specification (MILSPEC)- approved parachute constitutes a major alteration to that parachute.
A jumper who uses any type of AAD should be aware of its level of reliability and become fully proficient with the device. A prejump check should be made for proper setting, arming, and operational reliability to ensure proper functioning of the AAD.
When the situation requires use of the reserve
parachute, the jumper should always manually pull the reserve/auxiliary ripcord even when using an AAD.

[tetra316 0]

The agrument meant you have to follow the manual that is in effect at the date of purchase for it's intended use. Any other manuals that come out after you purchased your equipment do not apply since the equipment may have been modified by the manufacturer since you purchased yours thereby leading to the subsequent bulletins. So effectively any service bulletins and whatnot issued after you purchase your equipment do not apply, unless approved by the FAA.

[tetra316 0]

He was saying that yes installation must be approved by the manufacturer at the time you purchased the AAD. Any subsequent changes do not apply because the "contract/requirement" is only valid at the purchase date. If it's legal then it remains legal until an AD is issued by the FAA revoking that approval.

[Southern_Man 0]

Just a general question, has any rigger had any action taken against him/her for not packing in accordance with a SB/manufacturer's instructions?

"What if there were no hypothetical questions?"

[sundevil777 98]

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The agrument meant you have to follow the manual that is in effect at the date of purchase for it's intended use. Any other manuals that come out after you purchased your equipment do not apply since the equipment may have been modified by the manufacturer since you purchased yours thereby leading to the subsequent bulletins. So effectively any service bulletins and whatnot issued after you purchase your equipment do not apply, unless approved by the FAA.

Your argument would presume that a mfg cannot make any changes to their manual/instructions/whatever after the original manual. That is nonsense. The SBs issued by the mfg specifically include previously made equipment.

You don't seriously buy into the argument do you?

People are sick and tired of being told that ordinary and decent people are fed up in this country with being sick and tired. I’m certainly not, and I’m sick and tired of being told that I am

[tetra316 0]

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The agrument meant you have to follow the manual that is in effect at the date of purchase for it's intended use. Any other manuals that come out after you purchased your equipment do not apply since the equipment may have been modified by the manufacturer since you purchased yours thereby leading to the subsequent bulletins. So effectively any service bulletins and whatnot issued after you purchase your equipment do not apply, unless approved by the FAA.

Your argument would presume that a mfg cannot make any changes to their manual/instructions/whatever after the original manual. That is nonsense. The SBs issued by the mfg specifically include previously made equipment.

You don't seriously buy into the argument do you?

I'm not sure what I think now.

Again it's just strictly about following the letter of the law and what you can be held legally liable on.

[Southern_Man 0]

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The agrument meant you have to follow the manual that is in effect at the date of purchase for it's intended use. Any other manuals that come out after you purchased your equipment do not apply since the equipment may have been modified by the manufacturer since you purchased yours thereby leading to the subsequent bulletins. So effectively any service bulletins and whatnot issued after you purchase your equipment do not apply, unless approved by the FAA.

Your argument would presume that a mfg cannot make any changes to their manual/instructions/whatever after the original manual. That is nonsense. The SBs issued by the mfg specifically include previously made equipment.

You don't seriously buy into the argument do you?

I'm not sure what I think now.

But a very well respected DZO does. Again it's just strictly about following the letter of the law and what you can be held legally liable on.

I'm not sure that is a logical argument because I do not think that the regulatory power of the FAA over riggers is based on any sort of contract between the rig maker and the end user. The date of purchase is not relevant to what the rigger can do with his ticket.

"What if there were no hypothetical questions?"

[rhys 0]

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Meaning all gear that is initially approved for use by the FAA is legal. That no service bulletins issued after that fact, UNLESS also issued by the FAA, are legally mandated.

So also depending on what other countries have mandated and what the aviation authority in that country has written in their manual...

Unfortunately many of the part 149 (or similar) organisation freaked out and knee jerked by banning the argus at the drop of a hat without the adequate information to make a correct and informed decision...

This knee jerk will come accross as a wekness and it will take time for everybody to come up with an excuse of how they managed to be conjured into the banning so swiftly...

The whole thing is a clusterfuck and whether or not there is a fault in the units, the action and reaction was competely flawed and wrong...

So either the same treatment needs to me given to EVERY manufacturer from now on (not fucking likely) OR aviacom and all argus users deserve and apology.

Being a member of the PIA will be an advantage in such a situation, but that is anti competitive behaviour and illegal in my country.

Such rules should be fairly distributed and enforeced irregardless of who you are.

I hope Aviacom pursues a legal battle so we get some clarification on this issue.

Check out this video many of you would have seeen it before.

The result (in a real life situation) would equal a dead person.

It is a cypres in a vector micron, what was done????

This is very much the same result as a cutter not severing the loop = equals a fatality.

Fortunately this particular result was produced in a controlled envirionment.

check it out...

http://www.youtube.com/watch?v=ohBxepGxIxc

From that result under the same ratrionale as what has happened with Argus.... all microns with cypres should be grounded immediately..... before further investigation of the equipment....

FAIR IS FAIR!

I have nothing against vector, in fact they have helped me in the past, they are good rigs and I have 2 of them, and 6 sigmas with cypres...

I was just using this as an example of how this situation is not fair, and probably illegal!

"When the power of love overcomes the love of power, then the world will see peace." - 'Jimi' Hendrix

[JohnRich 4]

Even if your argument was correct that an Argus would still be legal in a rig, despite the manufacturer banning it - another problem is what the lawyers will do if you get sued due to an injury on an Argus-equipped rig. The plaintiff's lawyer will rip you to shreds, and you won't have much of a leg to stand on. That's why my DZO is replacing all his Argus-equipped rigs with Cypres, at the cost of many thousands of dollars. That may not be fair to Argus, but it's the reality of the U.S. court system.

[tetra316 0]

SBs are not mandatory. They are recommendations.

If they were mandatory why would the FAA ever issue ADs regarding any skydiving equipment? And they have.

[tetra316 0]

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Even if your argument was correct that an Argus would still be legal in a rig, despite the manufacturer banning it - another problem is what the lawyers will do if you get sued due to an injury on an Argus-equipped rig. The plaintiff's lawyer will rip you to shreds, and you won't have much of a leg to stand on. That's why my DZO is replacing all his Argus-equipped rigs with Cypres, at the cost of many thousands of dollars. That may not be fair to Argus, but it's the reality of the U.S. court system.

That's what I mean. It is legal to jump an Argus in any container even if there are so called bans. But it doesn't stop some lawyer trying to get around of the law and sue based on industry practice. The CYA way would simply be to comply with any SB.

[sundevil777 98]

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SBs are not mandatory. They are recommendations.

If they were mandatory why would the FAA ever issue ADs regarding any skydiving equipment? And they have.

The fact of it being a SB or AD is not at issue, I think.

The fact that riggers must follow mfg instructions is the issue. They don't have to call it anything other than "do it this way" in order for riggers to be required to do it, correct?

Some say that since AADs are not TSOd, that riggers are left to determine compatibility. If that were true, then even if a H/C mfg had always said that brand X AAD is not to be used in this rig, the individual rigger can still do what they want?

The enforcement mechanism is by way of the FAA acting against a rigger for not following mfg instructions, right?

I thought that ADs have to be followed by the user/skydiver, they are not just a requirement upon the rigger. Isn't that an important distinction?

I'm not a rigger, and don't know the intricacies of the code of federal regulations, so of course I'd like to get educated by those that are more aware of such things.

People are sick and tired of being told that ordinary and decent people are fed up in this country with being sick and tired. I’m certainly not, and I’m sick and tired of being told that I am

[riggerpaul 1]

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Meaning all gear that is initially approved for use by the FAA is legal. That no service bulletins issued after that fact, UNLESS also issued by the FAA, are legally mandated.

So also depending on what other countries have mandated and what the aviation authority in that country has written in their manual...

Unfortunately many of the part 149 (or similar) organisation freaked out and knee jerked by banning the argus at the drop of a hat without the adequate information to make a correct and informed decision...

This knee jerk will come accross as a wekness and it will take time for everybody to come up with an excuse of how they managed to be conjured into the banning so swiftly...

The whole thing is a clusterfuck and whether or not there is a fault in the units, the action and reaction was competely flawed and wrong...

So either the same treatment needs to me given to EVERY manufacturer from now on (not fucking likely) OR aviacom and all argus users deserve and apology.

Being a member of the PIA will be an advantage in such a situation, but that is anti competitive behaviour and illegal in my country.

Such rules should be fairly distributed and enforeced irregardless of who you are.

I hope Aviacom pursues a legal battle so we get some clarification on this issue.

Check out this video many of you would have seeen it before.

The result (in a real life situation) would equal a dead person.

It is a cypres in a vector micron, what was done????

This is very much the same result as a cutter not severing the loop = equals a fatality.

Fortunately this particular result was produced in a controlled envirionment.

check it out...

http://www.youtube.com/watch?v=ohBxepGxIxc

From that result under the same ratrionale as what has happened with Argus.... all microns with cypres should be grounded immediately..... before further investigation of the equipment....

FAIR IS FAIR!

I have nothing against vector, in fact they have helped me in the past, they are good rigs and I have 2 of them, and 6 sigmas with cypres...

I was just using this as an example of how this situation is not fair, and probably illegal!

Maybe all you say is true.

Maybe stronger action should have been taken in the case of problems in the past with other equipment.

But it is not about FAIR.

For all I know, the reasoning this time went like, "Remember that time the rig wouldn't open? We'd better not leave ourselves exposed like THAT again!!!".

I own an Argus and I own a Javelin. I don't much like what's happening, and I wish all had done better.

But it isn't about FAIR.

If they did it wrong before, that doesn't mean they must do it wrong again.

It sucks to be the ones in the situation into which we have been placed.

But it might be right. Maybe not fair. But maybe right.

[NovaTTT 2]

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Any other manuals that come out after you purchased your equipment do not apply since the equipment may have been modified by the manufacturer since you purchased yours

While modifications might take place, they will not be sufficient to violate the TSO under which the gear was authorized. My understanding is sufficiently different configurations and/or changes would require a new TSO.

But the manufacturer certainly can change their manuals and instructions retroactively, if they so choose.

It's their equipment and they have the FAA's blessing to set standards and procedures for the maintenance, repair and alteration of TSO'd gear.

It makes an interesting philosophical discussion, getting between the lines of these issues, but the only way to challenge the certainty of the FARs and their foundations would be in a court of law.

I can't believe anybody would willingly go there.

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

[NovaTTT 2]

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This is very much the same result as a cutter not severing the loop = equals a fatality.

The result is sort of the same, except the V3/CYPRES set up has the very real possibility of being deployed. The loop was cut - the CYPRES performed its job. An Argus would have had the same result in the same rig but maybe it would have locked the loop in the cutter.

So it's not about possible results, it's about causes. The video shows the effect of an overstuffed rig with a too long closing loop trying to escape through many grommets.

The Argus issue has to do with the AAD locking the container closed! That is not a container issue, that is an AAD issue.

So I think you're mistaken when you conclude the V3 video is related in any way to the Argus issue.

.02

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

[tetra316 0]

This is an email I received that better sums up what I was trying to get at along your points. This is why he buys into the agrument:

"I do. The manufacturers do not have the authority to legally declare their equipment un-airworthy. They cannot say that if you do not jump a pink jumpsuit, then your rig is grounded. The FAA is entrusted with that responsibility.

Regarding the 'must follow manufacturer's instructions', that is in reference to packing and maintaining, i.e. repairs. Compatibility of components is left up to the assembling rigger to determine. AAD's are not TSO'd.

All the FAA knows is aircraft and they treat parachutes as an aircraft. If Cessna issues a SB, it is not mandatory. only FAA issued AD's are mandatory.

A good example is my wife's Mirage. I did not move the Cypres cutter location per Mirage's SB because I don't use a closing loop that is too long and a manufacturer's SB is not mandatory.

Think of this, if SB's were mandatory, why would the FAA ever issue an AD? What's the point?

Giving manufacturers the power to ground their equipment is a conflict of interest. That is why aircraft manufacturers do not have that power.

Most skydivers simply believe SB's are mandatory or at least a good idea and riggers do not want to get caught out of the wrong side of a SB if something were to happen. Most DZO' require SB's to be followed to jump at their DZ. This creates an environment where SBs tend to be completed. So the FAA can leave it alone and not expend time money and other resources on a non-issue.

Remember that most skydivers, including several DZO's I've talked to, believe that a medical is required to be a tandem Instructor.

Get the FAA to say that they will not issue AD's for skydiving gear and that SB's are mandatory, in writing, and I'll change my mind."

[wolfriverjoe 1,400]

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SBs are not mandatory. They are recommendations.

If they were mandatory why would the FAA ever issue ADs regarding any skydiving equipment? And they have.

The fact of it being a SB or AD is not at issue, I think.

The fact that riggers must follow mfg instructions is the issue. They don't have to call it anything other than "do it this way" in order for riggers to be required to do it, correct?

Some say that since AADs are not TSOd, that riggers are left to determine compatibility. If that were true, then even if a H/C mfg had always said that brand X AAD is not to be used in this rig, the individual rigger can still do what they want?

The enforcement mechanism is by way of the FAA acting against a rigger for not following mfg instructions, right?

I thought that ADs have to be followed by the user/skydiver, they are not just a requirement upon the rigger. Isn't that an important distinction?

I'm not a rigger, and don't know the intricacies of the code of federal regulations, so of course I'd like to get educated by those that are more aware of such things.

MY UNDERSTANDING (and I welcome any correction of my understanding) is that installation of an AAD (to include pockets and channels) is considered a modification. Even if the manufacturer does it, it is an alteration from the configuation that was TSO'd.
That leaves it entirely up to the manufacturer to approve or not approve, or decide to rescind approval of a previously approved mod.(although the FAA can approve modifications, they usually don't unless there is no way to get manufacturer approval)

If the manufacturer has rescinded approval, that rig isn't legal to jump until the modification has been removed.

SBs can be recommendations or they can be mandatory (depends on the individual SB). But mandatory ones have the weight of "Maintained in Accordance with Manufacturer's Instructions" rules.

SBs come from the manufacturer, ADs come from the government. Some require immediate action (rig cannot be jumped until complied with) others are "next I&R" items. Both have the weight of the law behind them. ADs just come directly from the FAA and have a little bit more "Oomph" because of that.

Edit to add: You posted that e-mail while I was composing my message. Whoever wrote that is mistaken. There are MANDATORY SBs. And they have the full weight of the law behind them. The FAA issues ADs when they want to move faster than the manufacturer. Or cross over manufacturers. Or a variety of other reasons.

"There are NO situations which do not call for a French Maid outfit." Lucky McSwervy

"~ya don't GET old by being weak & stupid!" - Airtwardo

[JerryBaumchen 1,168]

Hi Tara,

I do not speak for the FAA; I do not have the authority to do so.

I did spend 30 + yrs working for the federal government as a technical contracts manager. While my duties varied, one of my duties was the approval/disapproval of Quality Programs and Inspection and Test Plans.

In 1979, a company that I own, obtained numerous TSO-authorizations for the production of parachute components.

During the process of obtaining a TSO, the FAA only approves one thing, and that is the Quality Program. They do not approve the test reports that must be submitted. They do not approve the specifications that must be submitted ( specifications are FAA-speak for what most of us would call drawings ). I believe, based upon my own experience, that they do look these documents over.

Also, the FAA does not approve Minor Changes to a parachute or parachute component. From Part 21 and found in a Final Rule dated 16 Oct 09:

§ 21.619 Design changes.
(a) Minor changes by the manufacturer holding a TSO authorization. The manufacturer of an article under an authorization issued under this part may make minor design changes (any change other than a major change) without further approval by the
FAA. In this case, the changed article keeps the original model number (part numbers may be used to identify minor changes) and the manufacturer must forward to the appropriate aircraft certification office, any revised data that are necessary for compliance with § 21.603(b).

IMO, a mfr can 'approve' anything that he/she chooses. Whether the FAA would enforce such an 'approval' is subject to debate; remember, only the FAA can speak for the FAA.

As of 16 Apr 11, there is a change to Part 21 that has required all PAH's ( PAH is a term the FAA uses for Production Approval Holders which includes holders of TSO-authorizations, PMA's ( which I understand are Production Manufacturing Authorizations ), and other approvals for the manufacture of certificated equipment) to have a new Quality Program approved by the FAA. I know because mine was finally approved early this year; and it took a lot of work & time to get it to where the FAA was OK with it.

When your friend sends you this:

The manufacturers do not have the authority to legally declare their equipment un-airworthy. They cannot say that if you do not jump a pink jumpsuit, then your rig is grounded. The FAA is entrusted with that responsibility.

I disagree. One of the things that I had to add to my Quality Program was some wording that if I were to discover that some materials, that had gone into production in any parachute component that I had produced, were later found to be deficient, I am req'd to issue a notice to ensure that the affected components are no longer in service. Your friends says that 'They cannot say that . . . a pink jumpwuit, then your rig is grounded.' I do not believe that this is applicable because the parachute mfr did not make the pink jumpsuit. I am of the opinion that the mfr, since they made the device ( in this case, the rig ), can legally declare their equipment un-airworthy.

I do find that many people used terms like 'modification, alteration, change, approval' without truly realizing just how changes are done with approved parachute equipment.

As I have mentioned before on this site, Bill Booth told me that the SkyHook was never submitted to the FAA as a Minor Change because he does not feel that he has changed anything.

It is quite possible that some harness/container mfr has taken the same approach and not submitted anything to the FAA when they have added the necessary pocket, channel, & elastic holder that would be for the installation of an AAD. Personally, I do not believe that the addition of those parts changes the configuration of the equipment and I do not see a need to submit the details to the FAA. But that is merely my opinion, and others may disagree with me.

Many years ago I had a rather long discussion with John Sherman of the Jump Shack and he told me ( and I agree with him on this ) that the only person who can determine if something is a Minor Change is the designer because only they know the details of their design. He felt that the FAA simply did not have the necessary knowledge to determine if something was a Minor Change or not. I agree with him on this.

If I were approached by a customer to inspect & repack her/his rig, in which there was a SB that had not been complied with ( i.e., in this case, the removal of the Argus AAD ), I would decline to repack it. IMO the legal & financial risks are just too great for the measly money that I make on a repack.

I live in Beaverton, drop me an email and stop by some time; I'll dazzle you with my other BS.

In conclusion, I am not the final authority in this discussion.

JerryBaumchen

PS) I once disapproved a potential supplier and that decision cost the US taxpayers $1.1 million dollars.