hackish 8 #1 February 5, 2015 The FAA lists a major repair as something that if improperly done might appreciably affect weight balance, structure, strength, performance,... flight characteristics or other qualities affecting airworthiness... Replacing a grommet is a minor repair... but suppose you're an idiot and leave a sharp edge and it cuts the reserve loop it meets the above criteria. I have a tuck tab with a broken piece of nylon inside. I assume this is a major repair even though I feel if it were done with a reasonable amount of skill to mimic the original it probably doesn't meet the criteria. What about if I need to replace a centre A line on a velo? Line replacements are supposed to be a major repair but with no cascade you simply replace a part. No sewing, no tacking nothing. How does a manufacturer do stuff? Not all of their people are master riggers. What if ACME pilot chute company makes a main pilot chute? Do it wrong and it could certainly cause trouble as above. Not a TSO'd part but still. How does the FAA consider manufacturing? I think you could argue either way on many items and I hate grey because I never know what side it belongs on. Where and how do you draw the line? -Michael Quote Share this post Link to post Share on other sites
skytribe 16 #2 February 5, 2015 Take a look at what is on the FAA practical test standards for Senior and Master riggers. Also take a look at the FAA Parachute riggers manual and once again work items which is applicable to each rating is clearly documented. Quote Share this post Link to post Share on other sites
masterrigger1 2 #3 February 5, 2015 Quote Take a look at what is on the FAA practical test standards for Senior and Master riggers. Absolutely! Quote Also take a look at the FAA Parachute riggers manual and once again work items which is applicable to each rating is clearly documented. Actually, that reference is a bad one. It lists certain major repairs as minor repairs. If you follow that reference a senior is led to believe he or she can legally work outside of their certificate. For Michael: A Senior rigger is a basic, beginning rigger. It is easier to list what you can do that what you cannot do. Basically you can assemble , inspect and pack parachutes, install simple patches not involving a seam (or even in the close proximity of a seam), replace Velcro, replace BOC pouches, replace grommets, and install AAD's that already have the provided pouches,etc. That pretty much sums it up. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
hackish 8 #4 February 5, 2015 The reason I asked is that the FAA manual (which I copied the criteria from) lists many repairs as senior rigger but the FAA released an AC at one point (Can't find it at the moment) that specifically said things like a line replacement was a Major repair. -Michael Quote Share this post Link to post Share on other sites
hackish 8 #5 February 5, 2015 MEL, What do you think about manufacturers? Like my ACME example above. Do you know where I'd find published info on what they can and cannot do or what qualifications they need? -Michael Quote Share this post Link to post Share on other sites
masterrigger1 2 #6 February 5, 2015 Quote What do you think about manufacturers? Like my ACME example above. Do you know where I'd find published info on what they can and cannot do or what qualifications they need? A manufacturer is required to follow the rules because the regs state that ANYONE (manufacturer or not) be a rigger or under the direct supervision of one to work on parachutes. ....And the rated person has to hold the appropriate certificate to do the work at hand. This is the reason there is at least one Master rigger at every manufacturer's location. I have attached the rule for you. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
mark 102 #7 February 5, 2015 hackishReplacing a grommet is a minor repair... but suppose you're an idiot and leave a sharp edge and it cuts the reserve loop. . . There is no repair that cannot be done so poorly as to create an unairworthy result. Quote What about if I need to replace a centre A line on a velo? Line replacements are supposed to be a major repair but with no cascade you simply replace a part. No sewing, no tacking nothing. If you search dz.com, you'll find several threads regarding who can do line repair/replacement on a main canopy. MEL and Dave DeWolf argue that line repair/replacement on a reserve is a master rigger task (and I agree), and therefore the same standards should apply to mains. My position with regard to mains is: (a) Since the original Poynter manual in 1971, we have always made a distinction between repair standards for mains and reserves, and in the certificate (senior or master) required. For example, Poynter Vol 1 7.25 Method 1, Replacement of Supension Line from Link to Link in Continuous Line Canopy, calls for a master parachute rigger on a reserve, but allows a senior parachute rigger to do the same task on a main. (b) Reserve parachutes have the characteristic of "airworthiness." They are tested to TSO standards, and manufactured to FAA-approved QC standards. Main parachutes, on the other hand, do not need to meet any performance or production standards. They do not have the characteristic of "airworthiness," that is, they are neither airworthy nor unairworthy. QuoteHow does a manufacturer do stuff? Not all of their people are master riggers. Riggers are not required for manufacturing. Adherence to an approved QC program is. QuoteWhat if ACME Cazer pilot chute company makes a main pilot chute? Do it wrong and it could certainly cause trouble as above. Not a TSO'd part but still. How does the FAA consider manufacturing? Main components, everything from risers up, can be made by anybody. QuoteI think you could argue either way on many items and I hate grey because I never know what side it belongs on. Where and how do you draw the line? Imagine yourself in court with Dan Poynter. Now imagine he's sitting at the other table. Mark Quote Share this post Link to post Share on other sites
mxk 1 #8 February 5, 2015 hackishThe reason I asked is that the FAA manual (which I copied the criteria from) lists many repairs as senior rigger but the FAA released an AC at one point (Can't find it at the moment) that specifically said things like a line replacement was a Major repair. -Michael AC-105-2E 15.c.2? It's still making a distinction between main and reserve: "The same kind of repair may be classed as major or minor depending on whether it is done to an approved or unapproved component. For example, replacement of a suspension line on a reserve canopy is usually a major repair, while replacement of a suspension line on a main canopy is generally considered a minor repair (even if the identical technique is required for both replacements)." Quote Share this post Link to post Share on other sites
hackish 8 #9 February 5, 2015 I was a little curious about an FAA published manual giving out information that I felt was incorrect. If you look at AC 105-2E it says the following: QuoteMajor or Minor Repair Determination. When there is a question about whether a particular repair is major or minor, follow the manufacturer’s instructions. In the absence of the manufacturer’s instructions, riggers should use the FAA’s Parachute Rigger Handbook (FAA-H-8083-17) and Poynter’s Parachute Manual Volume I and II as guides. If the procedure calls for a master rigger, it should be considered a major repair. If the procedure allows for a senior rigger, it should be considered a minor repair. That was published in 2013 so I wonder if it's been supersceded by any other clarifications? -Michael Quote Share this post Link to post Share on other sites
masterrigger1 2 #10 February 5, 2015 Quote a) Since the original Poynter manual in 1971, we have always made a distinction between repair standards for mains and reserves, and in the certificate (senior or master) required. For example, Poynter Vol 1 7.25 Method 1, Replacement of Supension Line from Link to Link in Continuous Line Canopy, calls for a master parachute rigger on a reserve, but allows a senior parachute rigger to do the same task on a main. The Poynter's Manual is not mistake free either.This is vivid proof and it also is not regulatory document. Your claim is that the FAA has two sets of standards. One for Mains and the other for reserves which is not true. They have only one set of standards which divides between major and minor repairs and who can do each or both.There is no distinction between a main parachute or a certified one. It just states "parachutes". Also, show us in the regulations where we can find where it states otherwise. Quote Riggers are not required for manufacturing. Adherence to an approved QC program is. You probably need to reread the document that I attached earlier. In no exaggerated manner does it state that a manufacturer is exempt from the rule. That rule applies to everyone. But you are correct on the QA part. Quote Main components, everything from risers up, can be made by anybody. Again, read the rule. Quote Imagine yourself in court with Dan Poynter. Now imagine he's sitting at the other table. ...or me which is actually looking like that will be the case. I have been subpoenaed in a pending case which actually has this exact content. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #11 February 5, 2015 Quote AC-105-2E 15.c.2? It's still making a distinction between main and reserve: "The same kind of repair may be classed as major or minor depending on whether it is done to an approved or unapproved component. For example, replacement of a suspension line on a reserve canopy is usually a major repair, while replacement of a suspension line on a main canopy is generally considered a minor repair (even if the identical technique is required for both replacements)." This is some of the bullcrap Mark and Sandy Reid had their hand in behind closed doors. It also is not regulatory and they knew it when they tried to "go-around" the regs. Regulations trump the AC BTW.... We are working on removing it now also. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
RiggerLee 61 #12 February 5, 2015 A couple of years ago I heard an interesting story during one of the meetings. I think it was the guy from buttler that stood up and was talking about an inspection from the FAA. If I understand correctly they were asking if Buttler was a "Repair Facility". It was in regards to maintenance and repairs being done to equipment being returned. In the end I think they did in fact simple make the argument that they had Master Riggers on staff. Where do Repair Facilities fall into this? LeeLee [email protected] www.velocitysportswear.com Quote Share this post Link to post Share on other sites
mark 102 #13 February 5, 2015 masterrigger1This is some of the bullcrap Mark and Sandy Reid had their hand in behind closed doors. The PIA Technical Committee meetings were open. Dave DeWolf and others were present at the outset and were specifically asked for their input. IIRC, you were included on email asking for additional input, even though you were not a PIA member at the time. All of Dave's suggestions were included, and he never objected to the stuff you and he object to now. Contrary to your allegations, none of this was done in secret, and all had the approval of PIA. You could have been part of the process; you chose not to be. Mark Quote Share this post Link to post Share on other sites
masterrigger1 2 #14 February 5, 2015 Lee, They are exactly the same. The only difference would be a non-national using their own gear or the US Military. The rules apply to everyone else. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #15 February 5, 2015 Mark, In the onset of the re-write, I along with several others that opposed what you had in the draft (which I still have BTW) submitted our rebuttals and never heard a peep from you guys. Quote IIRC, you were included on email asking for additional input, even though you were not a PIA member at the time I was a member at the time, then bailed mostly because of the lack of response from you guys. I then joined again and which I am still a member. Enough said. I will leave it until the Symposium. Also, I did just send you an email though. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
mark 102 #16 February 5, 2015 RiggerLeeA couple of years ago I heard an interesting story during one of the meetings. I think it was the guy from Butler that stood up and was talking about an inspection from the FAA. If I understand correctly they were asking if Butler was a "Repair Facility". It was in regards to maintenance and repairs being done to equipment being returned. In the end I think they did in fact simple make the argument that they had Master Riggers on staff. That's actually a reasonable issue. The skills required to build a rig (working on mostly flat pieces of new fabric until the container corners are boxed) are different than those required to repair. Mark Quote Share this post Link to post Share on other sites
hackish 8 #17 February 5, 2015 I'm finding this discussion quite informative. I once heard a story of a rigger being questioned on the stand. It went sort of like this: When we inspected this rig packed and sealed by you we found the fabric was folded like this. Why did you do that? Page 34. Excuse me? I said Page 34. What do you mean by that sir? On page 34 of the manual it says to do that. --- MEL, you're a professional witness called to comment if a senior rigger was permitted to do a repair. Rigger: FAA says check with the manufacturer or their document. Manufacturer went out of business in 2002. The FAA document here says authorized repairmen: senior rigger or master rigger. How would you argue against that logic? -Michael Quote Share this post Link to post Share on other sites
riggerrob 558 #18 February 5, 2015 MEL, We are going to have to disagree on this point. Many manufacturers believe that TSO approval allows them to do any repairs they want without the need to pay an arrogant, expensive Master Rigger. When I arrived at Para-Phernalia, I was an FAA Master Rigger. I offered to help train the current Senior Rigger and an apprentice to write their FAA exams, but they were not interested. The last time I visited Para-Phernalia, they did not have a Master Rigger working on site. OTOH Manley Butler is an FAA Master Rigger and used to closely supervise all the work in his factory. Sandy Reid is also a Master Rigger and kept an eye on everything happening in Rigging Innovations, plus all repairs had to pass production inspectors before they were allowed out the door. Quote Share this post Link to post Share on other sites
riggerrob 558 #19 February 5, 2015 CSPA defines the difference as whether or not you need a sewing machine. Introduction to sewing machines is covered in CSPA's Rigger A1 course. As for replacing plastic stiffeners in riser cover tuck tabs ... it is a bitch of a job without a binder set up exactly the same way as the factory. As for the repairs on your Tandem Vector 2, I cheated by unstitching the plastic early in the repair, repairing the container, rebinding the flap, installing a new grommet and resewing the plastic last. By pulling the plastic away from the binding tape, I vastly simplified the binding process. I learned that technique the hard way when repairing main top flaps on pre-2000 Javelins, Sidewinders, etc. Quote Share this post Link to post Share on other sites
riggerrob 558 #20 February 5, 2015 RiggerLee... "Repair Facility". ... Lee .................................................................................... The FAA quit certifying parachute "Repair Facilities" and lofts during the Clinton administration. Quote Share this post Link to post Share on other sites
hackish 8 #21 February 5, 2015 I like the simplification of CSPA for that fact but there are some positives and some negatives to the system. I really wanted to do the A1 course last year but this family man knows he would become a dead family man if he vanishes on Thanksgiving weekend. -Michael Quote Share this post Link to post Share on other sites
masterrigger1 2 #22 February 5, 2015 Quote MEL, you're a professional witness called to comment if a senior rigger was permitted to do a repair. Rigger: FAA says check with the manufacturer or their document. Manufacturer went out of business in 2002. The FAA document here says authorized repairmen: senior rigger or master rigger. How would you argue against that logic? First, A manufacturer cannot extend privileges to a person that does not own them by the FAA. It is the responsibility of the individual to stay within the confines of the certificate that he or she holds. In other words, a similar instance would be like a barkeeper or bartender telling a customer it is OK to drive home drunk... MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #23 February 5, 2015 Quote We are going to have to disagree on this point. OK Quote Many manufacturers believe that TSO approval allows them to do any repairs they want without the need to pay an arrogant, expensive Master Rigger. Many of them think wrong. Heck, half of them never knew that supervised reserve pack jobs were illegal. The other half (or more) used to build Non-TSO'd gear(knowly) and sell it.... MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
skytribe 16 #24 February 5, 2015 Quote *** Take a look at what is on the FAA practical test standards for Senior and Master riggers. Absolutely! Quote *** Also take a look at the FAA Parachute riggers manual and once again work items which is applicable to each rating is clearly documented. Actually, that reference is a bad one. It lists certain major repairs as minor repairs. If you follow that reference a senior is led to believe he or she can legally work outside of their certificate. There are things on the practical test standards which are marked as senior but are ultimately used in a repair that could result in a unairworthy situation. Looking at things such as fingertrapping, swaging etc. The riggers manual is a more up to date manual than Poynters which really is very old. I've read previous discussions on dropzone.com on this subject of certified/non certified equipment and what is permitted by riggers and under supervision of riggers etc. To me the big issue is that the FAA are so far behind the times in relation to parachuting. Recent trips to the local FSDO have merely reinforced the fact the FAA know very little about parachuting. That said, any work taken undertaken by an FAA rigger is a liability they open themselves up. I would say that if something was to crop up and I was in dispute that if I was able to provide a reference to one of the FAA own published recent documents that I would at least have somewhat of a leg to stand on, the documents do appear to be somewhat contradictory in areas. Quote Share this post Link to post Share on other sites
masterrigger1 2 #25 February 5, 2015 Quote To me the big issue is that the FAA are so far behind the times in relation to parachuting. Recent trips to the local FSDO have merely reinforced the fact the FAA know very little about parachuting. That said, any work taken undertaken by an FAA rigger is a liability they open themselves up. You could not be more correct. The problem is that MOST of the FSDO's do not care about us. The other side of the problem is that lawyers do take an interest. Quote I would say that if something was to crop up and I was in dispute that if I was able to provide a reference to one of the FAA own published recent documents that I would at least have somewhat of a leg to stand on, the documents do appear to be somewhat contradictory in areas. But at the end of the day, in court, the prosecuting attorney asks "Are you, as a Senior Rigger, allowed to do repairs that affect airworthiness?" You answer "NO" The next question would be "Was the deceased's parachute airworthy when the repair that you did failed and killed him?" or "Was the line set that you installed incorrectly really airworthy when it collapsed?" Better safe than sorry I guess. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
