FSDO requiring serial numbers for gear at a DZ?

[angryelf 0]

A DZ I frequent makes copies of the packing data cards and keeps them on file. This kind of irritates me, for several reasons. When I asked the DZO why he required this the response was "the FSDO mandated that I have all the information for rigs being jumped on file". I have not been able to reach the local FSDO concerning this, just wondering if anyone else has run into this before?

-Harry

"Sometimes you eat the bar,
and well-sometimes the bar eats you..."

[sundevil777 93]

Maybe it's their way of being able to absolutely show they had actually checked for all rigs to be in-date?

Not all packing cards will have all the component serial numbers on it, right? Do they really want the copy of the card for serial numbers or for repack date?

Maybe they've had experiences of stolen gear and wished they'd had more serial number info?

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

[stratostar 5]

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just wondering if anyone else has run into this before?

Only if I'm rigging your gear. Never seen a FSDO or other FAA person make any such demand on a dz, unless there was a rigging loft, the loft kept a master log for rigging, but no record of all gear jumped on the dz.

One the other hand, what is the big deal if your not jumping "hot" gear or 5 rigs?

you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

[mark 102]

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A DZ I frequent makes copies of the packing data cards and keeps them on file. This kind of irritates me, for several reasons. When I asked the DZO why he required this the response was "the FSDO mandated that I have all the information for rigs being jumped on file". I have not been able to reach the local FSDO concerning this, just wondering if anyone else has run into this before?

-Harry

91.307 requires the pilot to make sure rigs are in date. The issue is how to do this without the pilot personally checking data cards on every load. Most FSDOs are satisfied with a system in which a manifester checks the data cards and keeps jumpers with out-of-date rigs from manifesting. Many DZs use JumpRun or similar manifest software to keep track of pack dates. Your DZ obviously uses a different (or supplemental) system.

Before you call the FSDO, make sure you know what you are asking for. If you push the FSDO (like telling them some of the different ways to get around the controls), they may decide they'd like a perfect system -- like having the pilot check data cards before you load.

Mark

[beowulf 1]

I am trying to figure out what you don't like about it? Nearly every DZ I have been to has requested my reserve data card. If they choose to make a copy of it, so what. No skin off my ass.

[angryelf 0]

Asking for the card to check the dates is one thing. Copying the card, specifically to "have the serial numbers" on file seems very odd to me. I'm very familiar with having my data card inspected, as a traveling jumper I've been to DZ's in 26 states and expect no less as part of the gear check. I've never had any other DZ demand to make a copy of every card in every rig I plan to jump there. As the DZO in question is also a dealer/rigger I wonder if he is using my gear's serial numbers as a tax write off or something like that. As a rigger I find it annoying to have 5 different rigs that have different mains in them every weekend having the cards copied every time I stop by. The flustered manner in which I was told that the FSDO wanted the cards on file, the tongue tied manner in which it was described to me made me suspicious. I have not talked to the FSDO yet for the reason that was brought up in the thread a post or two back. Asking the feds if they are indeed requiring this could bring unwanted attention-agreed. Was just curious if this was common anywhere else.
As to copying the card as a rigger-that makes sense in a CYA sort of move. But the DZO in question is not maintaining my gear. I am.

-Harry

"Sometimes you eat the bar,
and well-sometimes the bar eats you..."

[beowulf 1]

The DZO isn't maintaining your gear, but it still would qualify as a CYA in case the FAA asked if the reserve card was checked as required.

As far as the whole tax write off thing, I find that kind of grasping for straws kind of reasoning and if he wants to cheat on his taxes it's only going to come around bite him the ass not you.

[angryelf 0]

That's fair. Just thought it odd. CYA is how everything must be done in this day and age... ;)

"Sometimes you eat the bar,
and well-sometimes the bar eats you..."

[chuckakers 370]

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91.307 requires the pilot to make sure rigs are in date.

Not true. The FAR's are written very vaguely, some would argue intentionally. The regulation says the pilot may not allow the jump unless the gear is legal (TSO'd, in date, etc.). It does not require that the pilot actually verify that it's legal. There is a difference.

If the gear is legal but the pilot doesn't verify it, the pilot has not busted an FAR.

Chuck Akers
D-10855
Houston, TX

[chuckakers 370]

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A DZ I frequent makes copies of the packing data cards and keeps them on file. This kind of irritates me, for several reasons. When I asked the DZO why he required this the response was "the FSDO mandated that I have all the information for rigs being jumped on file". I have not been able to reach the local FSDO concerning this, just wondering if anyone else has run into this before?

-Harry

I've never heard of a FSDO requiring ANY ongoing documentation of gear being jumped at a DZ.

With that said, if the DZO requires it, that's about it. If you don't like the rules, you have the option to jump elsewhere.

Chuck Akers
D-10855
Houston, TX

[skyjumpenfool 2]

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I've never heard of a FSDO requiring ANY ongoing documentation of gear being jumped at a DZ.

With that said, if the DZO requires it, that's about it. If you don't like the rules, you have the option to jump elsewhere.

And... if your gear ever gets stolen, I bet you'd be happy to have a copy of your pack card? Seems to me the positives outweigh the negatives. Besides, even this seems a small price to pay for a chance to jump out of someone's airplane.

Birdshit & Fools Productions

"Son, only two things fall from the sky."

[chuckakers 370]

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I've never heard of a FSDO requiring ANY ongoing documentation of gear being jumped at a DZ.

With that said, if the DZO requires it, that's about it. If you don't like the rules, you have the option to jump elsewhere.

And... if your gear ever gets stolen, I bet you'd be happy to have a copy of your pack card? Seems to me the positives outweigh the negatives. Besides, even this seems a small price to pay for a chance to jump out of someone's airplane.

A smart rig owner already has all that information recorded and kept in a safe place.

Chuck Akers
D-10855
Houston, TX

[DiverMike 5]

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If the gear is legal but the pilot doesn't verify it, the pilot has not busted an FAR.

That is true, but if the gear isn't legal and the pilot in command of the aircraft allows a skydiver to use it to "conduct a parachute operation", the pilot can definitely lose his ticket.

For the same reason I jump off a perfectly good diving board.

[chuckakers 370]

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If the gear is legal but the pilot doesn't verify it, the pilot has not busted an FAR.

That is true, but if the gear isn't legal and the pilot in command of the aircraft allows a skydiver to use it to "conduct a parachute operation", the pilot can definitely lose his ticket.

Uh, yeah. I know that. That wasn't my point. I was addressing a post where the poster INCORRECTLY said the pilot is responsible for "checking" gear to make sure it's legal.

No such requirement exists.

Chuck Akers
D-10855
Houston, TX

[tdog 0]

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a tax write off or something like that

Nearly impossible. The IRS will want to see the actual transaction on your credit card statement or bank statement where the money was spent. A packing data card does not prove you spent money on the thing, just that you have seen the thing.

I suspect the DZO is simply documenting their files to make sure, if you got hurt in a few months, and the packing data card was not with you at the time of impact, he could still prove you had it at one point and it was in date at the time of jump, even with a lost card.

[matthewcline 0]

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A DZ I frequent makes copies of the packing data cards and keeps them on file. This kind of irritates me, for several reasons. When I asked the DZO why he required this the response was "the FSDO mandated that I have all the information for rigs being jumped on file". I have not been able to reach the local FSDO concerning this, just wondering if anyone else has run into this before?

-Harry

I have seen this come in to play with a FSDO who is receiving complaints that a DZ is jumping, and allowing to be jumped, out of date equipment.

The DZ then starts paying attention to its gear and then executes a CYA move to prove things are AOK.

Matt

An Instructors first concern is student safety.
So, start being safe, first!!!

[riggerrob 558]

This is a common practice in Canada.
CSPA policy says that student and tandem rigs do not need packing data cards as long as the information is readily available. It is common practice to keep PDC in a filing cabinet in manifest.

Part of the reason is that students have an annoying habit of mis-placing cards.

The other issue is that it easier for manifest to keep track without leaving the office.

The last DZ - that I worked at - kept exhaustive records, including photo-copies of all work done on student gear, however, whenever she was in a hurry, the manifestress looked in my Rigger's Logbook.
Hah!
Hah!

[normiss 622]

Copy all you like, there are no serial numbers on my data card.

[tdog 0]

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Copy all you like, there are no serial numbers on my data card.

Wow...

I just read online a few FARs (§ 65.131 Records) and the Parachute Rigger's Handbook, and actually, the SN is not required in the FARs I read...

However, without a serial number, the packing data card has no way to be linked to the gear, and can be moved around. Thus I think the FAA could argue it is not an official card for that rig.

As a rigger, I would never want that liability, having a card that is signed with no gear linked to it. It would make me liable for every packed rig on the planet (or if the manufacture and model is listed, every rig of that design).

Further, I think the FAA kind of assumes all blanks on an approved form (as shown in the handbook and owner's manuals) should be filled out, and they might still not be happy even if the FAR does not say the record keeping required at the time of packing requires an SN.

Thus I wonder, why do you not put the S/N on your cards? If anything, in case of theft, it helps you, not hurts you to have these things documented.... The card is not a proof of ownership in any way, and the SN are not private info like an Social Security Number... Unless of course, you just like to have one card that covers all your rigs so you can prove everything you own is in date at all times.

[fcajump 153]

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This is a common practice in Canada.
CSPA policy says that student and tandem rigs do not need packing data cards as long as the information is readily available. It is common practice to keep PDC in a filing cabinet in manifest.

In the states a jumper can (and I have) been approached by an FAA inspector upon landing and asked for my PDC which must be on the rig. The DZ was fighting with other airport users for right to use the place, and inspections were not unusual.

(side note - they never found us in violation, good thing too... the fines can be expensive and CAN be levied against the jumper, not just the pilot.)

JW

Always remember that some clouds are harder than others...

[riggerrob 558]

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... I just read online a few FARs ... and actually, the SN is not required ...

"

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FARS are decades out of date.
Remember that FARS were originally written for pilot emergency parachutes.
Many manufacturers of PEPs stamped the same serial number on the harness, container, canopy and pilot -chute.
Ergo there is only one line per rig in old-style rigger's logbooks and old-style packing data cards really only have enough room to write one serial number.

OTOH Modern RLs and PDCs have three separate lines (harness/container, reserve canopy and AAD) and plenty of space to log service bulletins, factory inspections, battery changes, etc.
Modern riggers fill in all three sets of serial numbers.

Some european countries even require detailed PDC for main canopies.

[chuckakers 370]

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Copy all you like, there are no serial numbers on my data card.

Wow...

I just read online a few FARs (§ 65.131 Records) and the Parachute Rigger's Handbook, and actually, the SN is not required in the FARs I read...

However, without a serial number, the packing data card has no way to be linked to the gear, and can be moved around. Thus I think the FAA could argue it is not an official card for that rig.

As a rigger, I would never want that liability, having a card that is signed with no gear linked to it. It would make me liable for every packed rig on the planet (or if the manufacture and model is listed, every rig of that design).

Further, I think the FAA kind of assumes all blanks on an approved form (as shown in the handbook and owner's manuals) should be filled out, and they might still not be happy even if the FAR does not say the record keeping required at the time of packing requires an SN.

Thus I wonder, why do you not put the S/N on your cards? If anything, in case of theft, it helps you, not hurts you to have these things documented.... The card is not a proof of ownership in any way, and the SN are not private info like an Social Security Number... Unless of course, you just like to have one card that covers all your rigs so you can prove everything you own is in date at all times.

FAA officials are obligated - and routinely hell-bent - on following the FAR's and their guidance, no more, no less. Except for the occasional over-bearing type, every FAA official I've ever worked with (and there have been dozens) only wanted to enforce the letter of the law. I have seen very few that try to reach beyond the regs, and when I have they were easily backed down with their own documentation and rules.

The packing card is not the important document. The rigger's log is. If an FAA official wants verification that the card goes with the rig, he/she need only to contact the rigger whose seal code is on the data card. The rigger can confirm he/she certified THAT rig as airworthy per the FAR's and can also confirm that the card goes with the rig with the following REQUIRED information from the rigger log:


(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.

Push come to shove, I suppose the fed could request ID from the jumper who claims it's his or hers to insure it matches the owner listed on the riggers log, but I think that would only happen if the fed suspected foul play with the documentation.

These FAR's have worked just fine for years and aren't "broke". Let's not over-think things and invite the feds to scrutinize us more than they already do.

Chuck Akers
D-10855
Houston, TX

[tdog 0]

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These FAR's have worked just fine for years and aren't "broke". Let's not over-think things and invite the feds to scrutinize us more than they already do.

I totally agree. I think the best way to do that is to continue to completely fill out industry standard paperwork, such as the packing data card even when not required, so the FAA in case of a fatality or other investigation does not find holes in their own rules.

[chuckakers 370]

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These FAR's have worked just fine for years and aren't "broke". Let's not over-think things and invite the feds to scrutinize us more than they already do.

I totally agree. I think the best way to do that is to continue to completely fill out industry standard paperwork, such as the packing data card even when not required, so the FAA in case of a fatality or other investigation does not find holes in their own rules.

Sure. Go ahead and give 'em an inch....

Chuck Akers
D-10855
Houston, TX

[base1325 0]

If you don't like it jump somewhere else.