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GLIDEANGLE

USA: Rigger required for MAIN work... enforceable?

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The FAA went to great lengths to change the FARs (14 CFR) to make clear that maintenance or alteration of a MAIN canopy can only be done by, or under the supervision of, a certified rigger.

Given that no records are required of maintenance or alterations of MAIN canopies, how is this enforceable? It seems to be pointless to me.

14 CFR 65.111.c

"(c) No person may maintain or alter any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person—

(1) Has an appropriate current certificate issued under this subpart; or

(2) Is under the supervision of a current certificated parachute rigger;"


14 CFR 65.125.c

"(c) A certificated parachute rigger need not comply with §§ 65.127 through 65.133 (relating to facilities, equipment, performance standards, records, recent experience, and seal) in packing, maintaining, or altering (if authorized) the main parachute of a dual parachute pack to be used for intentional jumping."

Both of the above regulations can be found here:

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=14:2.0.1.1.4&idno=14#14:2.0.1.1.4.6.1.1

The section of the Federal Register where this change was made:

http://www.uspa.org/Portals/0/News/Part%2065%20FR.PDF
The choices we make have consequences, for us & for others!

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Hi GLIDE,

IMO only, it is absolutely unenforceable. And that is why I think it is truly a dumb thing.

Lets say some non-rigger does a whole bunch of work on a main. Some unknown person writes to the FAA and tries to turn him in.

The FAA contacts this non-rigger and he merely says, "I refuse to respond due to my 5th amendment rights."

Then what can the FAA do? The non-rigger can deny ever doing it; after all there is no paper trail.

JerryBaumchen

PS) Now let the flame wars begin. :P

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I think it is MOSTLY unenforceable. If someone who was not a rigger was charging people for canopy repairs and got someone killed because of his shoddy work, I can see where they could throw some federal charges at him. It would be tough but theoretically possible.

That being said I've never heard of anyone ever being questioned about it. In the 90s I was questioned about packing mains... which is sort of in the same ballpark but our Master rigger was close by and was able to show that I was under supervision.

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Wendy, it's always been like this. In 2001 when the FAA added tandems they screwed up the language and made it possible for the next person to jump it to alter a main. This was NEVER intended. This was corrected on an 'emergency' basis by the FAA in the 2010 change. USPA got upset that they didn't know this was going to happen. USPA personnel DID know it was wrong and the FAA intended to change it but before Randy Ottinger joined. It took the FAA 9 years to correct a mistake. About 8 years after they knew about it and called it an emergency. (per FAA DC personnel)

A lot of jumpers thought the FAA was taking something away. They weren't. They were correcting there mistake in writing English and IF it could be enforced probably would have enforced the previous language anyway since there was never an intent to change it in 2001.

To the op, since there are no record required it is unenforceable, but still the law.
I'm old for my age.
Terry Urban
D-8631
FAA DPRE

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JerryBaumchen

Hi GLIDE,

IMO only, it is absolutely unenforceable. And that is why I think it is truly a dumb thing...


...PS) Now let the flame wars begin. :P



I agree that it is absolutely unenforceable. But I'm not sure it's totally useless.

Some people actually obey the rules without the threat of penalties.

I've had people ask me why they can't do a simple seam restitch on a main canopy. One guy wanted to do it by hand with a needle and thread (this was actually on a slider, not a canopy).

Being able to say "because the rules say it has to be done by a rigger" is, IMO, a good thing. It helps reduce bad repairs by unqualified people.

No flames from me, just an opinion.
"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

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Hi Joe,

Here is why I take the position that I do.

Quote

One guy wanted to do it by hand with a needle and thread



That same guy could start with any fabric he wanted, any thread that he wanted and then build his own canopy ( or 10,000 of them for sale to anyone ) by hand with a needle and thread. And no two would need to be the same.

But, then along comes the FAA and says that anyone who works on it must have a Master Rigger ticket.

If that is not absurd then nothing is.

And no flames back at you either,

JerryBaumchen

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JerryBaumchen

Hi Joe,

Here is why I take the position that I do.

Quote

One guy wanted to do it by hand with a needle and thread



That same guy could start with any fabric he wanted, any thread that he wanted and then build his own canopy ( or 10,000 of them for sale to anyone ) by hand with a needle and thread. And no two would need to be the same.

But, then along comes the FAA and says that anyone who works on it must have a Master Rigger ticket.

If that is not absurd then nothing is.

And no flames back at you either,

JerryBaumchen



Is a Master ticket required? (honest question)

I have done a couple of minor repairs - Seam re-stitch and such. Nothing that would "affect the airworthiness of the canopy", just stuff to prevent further damage.

Wouldn't that fall under Senior Rigger privileges?
"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

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wolfriverjoe

I have done a couple of minor repairs - Seam re-stitch and such. Nothing that would "affect the airworthiness of the canopy", just stuff to prevent further damage.

Wouldn't that fall under Senior Rigger privileges?



A main canopy does not have "airworthiness." "Airworthiness" is a characteristic of TSO'd components only. An airworthy component is one that meets its certification standards, and mains are not certified.

A main canopy is neither airworthy nor unairworthy. No one can do a repair that would affect a characteristic it does not possess. Whatever repairs you as a Senior Rigger might do would all be minor repairs.

You need a rigger certificate to maintain a main canopy, but your certificate does not limit what main canopy repairs you can do. Your knowledge, ability, equipment, and materials do. Work within your limits.

Mark

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Quote



But, then along comes the FAA and says that anyone who works on it must have a Master Rigger ticket.



Actually they say you must have a appropriate certificate to do the work.

Minor repairs- Senior or master rigger

Major repairs - Master rigger or senior under the direct supervision.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Quote


A main canopy does not have "airworthiness." "Airworthiness" is a characteristic of TSO'd components only.



You need to show me and the others this in writing!

Experimental airplanes are not TSO'd for example and they have an Airworthiness Certificate issued by the FAA.

This is the exact crap that we are getting removed out of the last AC that was published. Which by the way is not regulatory; The FAR's are.

Quote


You need a rigger certificate to maintain a main canopy, but your certificate does not limit what main canopy repairs you can do.



Again, are you teaching your students that senior riggers can do major repairs?

....and not not come back with the bullcrap that major repairs on a main are to be considered minor repairs.
That is also being removed from the AC

Airwothiness is defined as basically being able to maintain flight and does not divide between a main or certificated canopy.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

Experimental airplanes are not TSO'd for example and they have an Airworthiness Certificate issued by the FAA.



On the other hand, ultralights do not have Airworthiness Certificates. I agree that if there were such a thing as an experimental reserve, it should have some sort of Airworthiness Certificate.


masterrigger1

Airworthiness is defined as basically being able to maintain flight and does not divide between a main or certificated canopy.



You need to show me and the others this in writing!;)

Mark

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mark


***Airworthiness is defined as basically being able to maintain flight and does not divide between a main or certificated canopy.



You need to show me and the others this in writing!;)

Mark

You could also argue that the parachute cannot maintain flight, it will fall out of the sky at some point. :P
"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
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I've always thought that the 103 analogy is interesting. With out a doubt a main canopy meets all the criteria of a part 103 unpowered ultra light vehicle.

I think the idea of a TSO for reserves and harnesses and reserve containers comes from their origin as pilot emergency rigs. An emergency rig is something that any person should be able to put on and have a reasonable expectation of it working as advertised within the expected parameters. It's the protecting the uninformed public concept that the FAA itself seems to have been based upon.

Now lets look at part 103. As a single seat vehical, not aircraft there are absolutely no, I repeat no standards for airworthiness of any kind. Even the "reserves" are not TSO'ed. The FAA has absolutely no interest in them. The only standard that exist are internal to the industry or there equiv of the USPA. There are absolutely no restrictions on the work performed on them.

If it were all to start today with no history of conversion from or use of existing emergency rigs I think the FAA would just call the whole system a part 103 ultralight. The only systems they would concern them selves with would be Tandoms. Maybe comercal rigs, ie student/rental rigs. There would be strong precedents for this. You know it makes me wonder if you could build your self an "Air Launched Ultra Light Vehical" and forgo the whole TSO thing. I mean honestly, How is that illegal? An ultra light does not have to be capable of ground launching. It can be towed up of "air launched" of the edge of a cliff. So how is a single harness rig any different? It doesn't even have to have a reserve. Many ultra lights don't. It could be a base rig. It can be sold or purchased fully assembled. The only things it could not do are be used commercially, no demos or students, or be jumped over a "congested area", definition a bit sketchy.

I'm not saying that it's this way. I'm just saying, look it. I'm not eaven making the argument that we'd be better off. But the main canopy and main tray have a lot more heritage from the part 103 ultra light then from any "Certificated Aircraft" An "Aircraft" by definition has an airworthiness certificate. It is awarded based upon it's compliance with set standards depending on category. Nothing like that exist for mains and you should thank your stars that it doesn't exist. Even part 21 "Experamentals", you probable mean 51% rule, have some form of standard. 40 hours of flight on the engion/prop combination. And even with them, if you build it you can perform all your own matinance and annuals. Why can't a guy build his own Main? And if he does he is the manufacture. Are you saying he has to be a rigger? Let's muddy the water even more. What about subcontracting work as the manufacture? I'll give you some precedents. Subcontracting cutting of fabric, hell how about the weaving of fabric. Subcontracting the sewing then attaching lines to canopies. Hell whole canopies, even reserves, have been subcontracted. How about the kits to turn your 7 cell into a nine cell. Remember those? Did they require a rigger? You want something more recent? How about when PD built canopies for a base manufacturer which were then "finished" by the base company. The "finishing" consisted of sewing a tail pocket on and sewing on Logos on the side panels.

My point is that there are ample presedents for how we have always treated main canopies like part 103 ultralights. How is taking the fabric of the canopy and adding a line set any different. I argue that you have just "built" a canopy from subassibleies and that you are the "manufacture". Did you have to have a contract with your suppliers? Did the 7 to 9 cell guy have any sort of agreement with the original builder?

I flatly do not like the way things are going. I feel that it will be restrictive to some of us. It means that a crew dog can no longer modify his risers. It means a CRW team can not change the trim of their canopies. Not to mention the patches. It means a wingsuiter can not open the corners of his tray. Forget changing out bags to a aftermarket simi stowless or a speed bag. You can't even change out to an after market pilot chute. That's an alteration to the system and could deffenently affect air worthiness.

It may have been a miss print but we were better off before their "correction" It actually made for a better standard. You're the next one jumping it, it's on you. It's a much better idea then some totally unenforceable rule. Unless you want to go the Euro route and have a full logbook for all work done on the main or main tray.

And what the hell is "Airworthiness" any way. I'll make it easy. Show me a "standard" that includes EVERY canopy that has been sold on the market. I'll make it even easier, show me a standard that includes every canopy currently being jumped today. Try doing that with out grounding half the mains out there.

So I guess what I'm asking is do we really want to go this way?

Lee
Lee
lee@velocitysportswear.com
www.velocitysportswear.com

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Sadly, sport main parachutes are mentioned in the FARs and it takes an act of Congress to change a FAR.
If the truth were told, the FAA does not want to waste its time enforcing FARs about main parachutes.
My cat knows more about main parachutes - than 99 percent of FAA employees - because she has seen more mains being packed.
Most of the trolls ... er ... skydivers - who waste time on this debate - spend more time on keyboards than sewing machines ... and I would not trust them to sew pillow cases.

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wmw999

Dunno which would be worse -- FAA jail, or being a CRW dog :)

Wendy P.



...................................................................................

Being surrounded bu arrogant, aggressive, profane men who suffer from an excess of testosterone?
How can you tell the difference from ...????

Oh!
Sorry, I was describing the Canadian National CReW Team.
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Hah!

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Tandems were considered "experimental" by the FAA until not too long ago. They were definitely TSOd.


mark

***Experimental airplanes are not TSO'd for example and they have an Airworthiness Certificate issued by the FAA.



On the other hand, ultralights do not have Airworthiness Certificates. I agree that if there were such a thing as an experimental reserve, it should have some sort of Airworthiness Certificate.


masterrigger1

Airworthiness is defined as basically being able to maintain flight and does not divide between a main or certificated canopy.



mark

You need to show me and the others this in writing!;)

Mark

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Quote

Most of the trolls ... er ... skydivers - who waste time on this debate - spend more time on keyboards than sewing machines ... and I would not trust them to sew pillow cases.

Most of those trolls ... er ... skydivers wouldn't think of trying to do anything their systems, either.

But it was the people who thought about their gear and experimented that came up with some great (and some awful) ideas in the past. I'm not sure that actively trying to prevent that in the future is a good thing.

Wendy P.
There is nothing more dangerous than breaking a basic safety rule and getting away with it. It removes fear of the consequences and builds false confidence. (tbrown)

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Not to add any fuel for debate but just to clarify, in the states, homebuilt aircraft receive a special airworthiness certificate for a one off build. Which is different than factory serial certificated aircraft. Any significant changes or mods at a later date to the homebuilt and the aircraft must re enter a test phase.

Factory craft either meet spec or don't. Factory craft have annual inspections. Home built/ experimentals have a condition inspection. Different paper work, different process. This is very confusing to owners/ non-builders a great majority of A&Ps that get hired by non builders to annual an experimental and not supprisingly many many FAA personnel involved.

FAA people that are interested in aviation and have a facination with the homebuilt side can be very helpfull. FAA personnel that are just collecting GOV pay and trying to interpret a confusing set of FARs get very lost themselves and can set a homebuilt project back years.

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Hi Rob,

Quote

If the truth were told, the FAA does not want to waste its time enforcing FARs about main parachutes.



From personal experience, whenever I'm having lunch or just talking to the FAA personnel that I deal with, when I ask them to 'take off their FAA hat' and talk; invariably everyone of them has said that they would love to get completely out of the entire parachute thingy.

I think PIA should get proactive and take this issue up.

Hint/hint, Mark. B|

JerryBaumchen

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JerryBaumchen

From personal experience, whenever I'm having lunch or just talking to the FAA personnel that I deal with, when I ask them to 'take off their FAA hat' and talk; invariably everyone of them has said that they would love to get completely out of the entire parachute thingy.

I think PIA should get proactive and take this issue up.

Hint/hint, Mark. B|



If you want a certification system, we're better off with the FAA doing it. PIA and/or USPA could set up a rigger certification system and/or an equipment certification section, but we'd literally have to pay for it. Right now, we get a free ride from the FAA.

On the other hand, if you'd like to do away with certification altogether, I'll agree. Any number of recreational industries do fine without the level of oversight we get from the FAA, and I don't think the parachute industry is any different.

Jerry, do you think we can get the manufacturers, USPA, DZOs, and jumpers on board with our program?

Mark

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