Master or Serior ticket to make a repair?

[masterrigger1 2]

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The only sewing required is to bind the backpad with E thread after creating the opening for the strap. Otherwise it is just an assembly of factory components. I'm sure you will say this is a modification, however I would disagree with that as well. When they changed the design from the factory and began mandating this retrofit it went from being a modification to an update with factory parts. This is no different than cutting the tip of the stiffener in an older wings and re-sewing the flap which a senior rigger can do.

If you read the definitions i just posted, you might have a different view.

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I would say the manufacturer is in a much more competent position to determine what is a major or minor repair on their own system than the FAA that doesn't particularly understand what we do.

Maybe.
But over the years some of them were the worst at specifying who could do the work. One manufacturer for instance, quoted that a senior rigger could modify a freebag and install loops for rubber bands. I think that has since been rectified or changed, but not totally sure.

The same applied to the aircraft industry, so if you will read AC 43-210 (in it's entirety), you will see that the ASI is the person that determines what the repair or modification is to be classified as.

ASI is Aviation Safety Inspector BTW...

And if you read further, you will see that the ASI may ask the manufacturer for help in this case.

But the ASI is the responsible party for that task.

Note: For Jerry as well


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[skytribe 16]

The rules we have established are outdated and written when much of the parachuting gear was modified military surplus gear. That is not the case anymore and clinging to an outdated FAA definition (which you have agree has outdated and contradictory information and very little experience or interest in regulating sport parachuting) as the crux of your argument is definitely your opinion of how all these contradictory information ties together.

You appear to cling to this definition with regard to effecting airworthiness.

masterrigger1

But it is not MY interpretation; it is the FAA's by their own definiton.
That is the whole point.
Here's their definition of a major repair:

z. Major Repair. A repair that, if improperly done, might affect weight, balance, structural
strength, performance, powerplant operation, flight characteristics, or other qualities affecting
airworthiness, or is not done by accepted practices or cannot be done by elementary operations.

Whilst I understand the rules - I'm able to assemble equipment and assess compatibility. I'm able to reorder lines on the links and change hard links to soft. Any of which when improperly done could effect the airworthiness. (Yes I could not do up the links or incorrectly assemble the slink)

Hell, I even pack the reserve, which if improperly done could effect the airworthiness of the gear as I could pack it in such a way that it wouldn't open.

So what can a senior rigger do in your opinion that if improperly done could not cause an unairworthy situation. As I'm sure that almost everything you would say someone could come up with a way they could do it improperly and affect airworthiness.

The summary is that the definition is weak and ambiguous to start with. The later FAA documents and practical test standards are showing tasks that can be done by senior riggers and of which could be done incorrectly and effect airworthiness. The test is surely to make sure that applicants know how to do things the correct way.

As far as manufacturing goes - do I need to be a master rigger to manufacture items ?. If you say yes or under the supervision then where do you draw the limit. Can I manufacture a closure loop (main or reserve). Can the manufacturer state that this is Ok for me to do or do I need to order every thing from a manufacturer or master rigger. Its taking things to an extreme. I'm sure you can find some FAA regulation which you can apply to this.

[riggerrob 558]

I am backing McCordell and Baumchen on this issue.

The confusion started with debate over whether adding a Y-strap is an alteration. May I further muddy the waters by introducing the terminology of "minor alteration" and "major alteration?"
Adding a Y-strap to a Sigma tandem student harness is a "minor alteration" because most of the sewing was already done at the Sigma factory. A Sigma Y-strap can be installed by an FAA Senior Rigger because it is a series of "elementary operations," with only a little non-structural sewing to close the back-pad.
OTOH installing a Y-strap on a Strong tandem student harness is a "major alteration" because it involves un-picking lots of stitching, then sewing the new Y-strap to the shoulder straps and leg straps with 5 cord and then sewing the leg-pads and back-pad closed. Since Strong requires structural stitching, it is a "major alteration." Back when Strong introduced the Y-strap, I sewed (using factory drawings) them onto 20-some-odd student harnesses.

I define the difference between "minor" and "major" by the type of sewing machine required. I define "major" as requiring a Class 7 (5 cord) or bar-tacker (E thread).
Performance Designs will back me on this, because PD says that any "major" repair requiring bar-tacks (e.g. line attachment tapes) must be returned to the factory.
Since few part-time FAA Senior Riggers are going to invest in bar-tackers or harness machines, this becomes a purely intellectual debate.

[skytribe 16]

I would tend to lean in the same direction as RiggerRob.

That said by his definition of use of 5 cord / bar tacker. I would say that also has exceptions. Say I reline a xaos with a factory lineset that is all continuous lines. So no bar tacking required. Simply larks heading the lines onto the attachments. Master or Senior ?

Its more that for every rule, there is probably an exception. Perhaps the fact that the manufacturers specifically determining rigger level is a better idea, for obsolete manufacturers then the FAA rules could apply as a fallback.

With regard to the Strong Y Mod, as usual strong over engineer the design making it more complicated than it needs to be. Its a shame they don't apply much effort in R&D and improving the fundamentals of there products.

[masterrigger1 2]

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May I further muddy the waters by introducing the terminology of "minor alteration" and "major alteration?"

Yep. you are just muddying the waters further.
No matter because an alteration of any degree is only permitted by a Master rigger or someone under his supervision by the regulations.

You are offering opinions; I am am directing you to official definitions and regulations.

Quote

I define the difference between "minor" and "major"

Your opinion and the FAA's definition differ greatly.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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With regard to the Strong Y Mod, as usual strong over engineer the design making it more complicated than it needs to be. Its a shame they don't apply much effort in R&D and improving the fundamentals of there products.

Spotty,

I am good with the over engineering on my end.
While I am not a fan of the TNT system, I do like the older DHT. Yes,it needs some updates, but at least I do not have to worry about having baglocks on the main which is a big issue on other systems.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[skytribe 16]

Off topic and different discussion but I jump at a busy DZ using hawks (probably 14 online). They are always requiring ongoing maintenance. Drogue and kill lines breaking, d bag binding tearing out. Velcro on instructor release design that results in damage to MLW. Even stuff that comes back from Strong has issues, friction adapters installed in reverse.

Strong's adamant position not to pro-pack the reserve and its crazy sidepack/roll pack approach. The hotdog style leg pads which are the most uncomfortable legstraps ever installed. The freebag design that uses bungees and tensioners rather than a more common approach of safety stow etc. How many reserve containers still continue to use Velcro to close the container. The approach can only lead to line damage if not careful when closing the container.

The NEW drogues we have received recently are a different design and simply are a more over complicated design which will not solve the fundamental problems of kill lines breaking or wearing quickly or even making replacement easier.

I am certified on both UPT and Strong equipment and have 1000's of tandem with the vast majority are on strong. That said, I don't think much of there continual product development with engineering , R & D or QA of the company. History is great but we are talking today and advances that have been made. I believe Strong are just using the Tandem products as a cash cow.

My opinion is it doesn't need product updates but a fundamental redesign much like UPT did with the Sigma. TNT may be that but it appears too little too late and even in the marketing pictures looks like crap. I don't have faith that Strong have that expertise any more and based upon repairs come back from them I don't believe there QA is up to scratch.

Different subject though.

[piisfish 135]

skytribe

Say I reline a xaos with a factory lineset that is all continuous lines. So no bar tacking required. Simply larks heading the lines onto the attachments. Master or Senior ?

you don't need a rigger for that :-)

scissors beat paper, paper beat rock, rock beat wingsuit - KarlM

[skytribe 16]

Quote

you don't need a rigger for that :-)

Exactley.....

[masterrigger1 2]

Quote

Say I reline a xaos with a factory lineset that is all continuous lines. So no bar tacking required. Simply larks heading the lines onto the attachments. Master or Senior ?
you don't need a rigger for that :-)

Negative.
I would say you guys did not read the text in the 65.111 interpretation that I posted earlier.

....Which is BTW the LEGAL interpretation by the FAA and not my opinion.


From the posted 65.111 Interp:

Only certificated riggers, or persons
under their supervision, have the
requisite knowledge and skill to safely
perform maintenance and alteration.
The FAA does not intend that the
regulation be interpreted to authorize
maintenance and alteration by those not
qualified, nor otherwise appropriately
supervised. The FAA’s intention is
clearly supported in other parachuterelated
regulations (see 14 CFR 91.307,
105.43(a), and 105.45(b)(1)). All of those
regulations support the FAA’s position
that in all but ‘‘next jumper’’ situations,
parachute packing must be
accomplished by or overseen by an
appropriate current certificated
parachute rigger. Further, none of those
sections authorize maintenance or
alteration of parachutes by noncertificated
persons


There is more there if you guys care to read it.


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[tdog 0]

riggerrob

I define the difference between "minor" and "major" by the type of sewing machine required. I define "major" as requiring a Class 7 (5 cord) or bar-tacker (E thread).
Performance Designs will back me on this, because PD says that any "major" repair requiring bar-tacks (e.g. line attachment tapes) must be returned to the factory.
Since few part-time FAA Senior Riggers are going to invest in bar-tackers or harness machines, this becomes a purely intellectual debate.

I disagree as before I had a rigging ticket of any kind, I had access to the machines you mention and was trained on their operations and frequently used them to repair things from jumpsuits, wingsuits, and even my gear (with advice and instructions from riggers when appropriate).

Plenty of senior riggers have access to dz lofts with tons of machines too, so it is more than an intellectual debate, but real world application. I know a former senior riggers (deceased) who would kick out 10 linesets a week...

I re-read the manuals PD has on their website today to refresh my memory (call it continuing education). Haha

The RESERVE manual suggests linesets be replaced at the factory, but a Master may do it. It further explains bartacks must be done at the factory because of a proprietary stitch pattern, needing templates for locations, and having to replace fabric damaged by the old tack. PD appears to back the concept "no rigger" has the skill or tools in the field to do a factory repair, not one that suggests "those who own equipment, such as master riggers or dzos."

On the otherhand, the MAIN manual does not mention riggers much at all, other than "you or your rigger should inspect" and "your rigger should assemble" but without a mandate that they must.

I dug thru the website looking for work instructions for main canopy repairs, and found a document on how to modify a pulse to version 2. http://www.performancedesigns.com/docs/Pulse_190-260_Revision_P01_to_P02_upgrade_Work_Instruction.pdf and it is silent to the type of rigger involved, but very specific on materials and equipment.

I searched for other PD official documents regarding mains looking for any factory advice on what they feel is the qualified rigger for repairs to mains, and I did not find any that back your claim that PD would back you. please feel free to send me links, I will read and add to my library.

[pchapman 261]

To the thread in general:

The summary in my head for this whole thread (and other previous ones with MEL laying down the law) is basically:

A: "The FAA doesn't allow jumpers to do very much at all to rigs, and senior riggers also very little... far less than jumpers, riggers, and manufacturers commonly actually believe they can perform or actually perform in standard practice."

B: "But the FAA are idiots who don't know anything and are out of touch with the way the sport works. "

A: "That may be true, but they still make the rules."

B: "But the FAA say so many things in different sources of theirs that are contradictory, allowing all sorts of things in some of them -- so I'll take those opportunities. And the manufacturer allows certain work too."

A: "That may be true, but officially one has to take the most official documents like the CFRs/FARs and use the most restrictive requirements they list. And what the FAA says is law, not what the manufacturer says."

Then in the end everyone makes their own choice about how much to ignore the FAA. You have a lot on the line and get queasy about liability? Maybe follow their rules more closely. You can walk away from it all and think a lawsuit is unlikely or bullshit? Ignore the FAA and follow industry standards.

"Well, your honor, I followed the FAA's Rigger Manual AND what the manufacturer stated in its bulletin, AND standard industry practice. If the FAA now says differently, I don't know anything about that."

You decide if that's likely to ever happen or be a good enough defense.

[masterrigger1 2]

Quote

To the thread in general:

The summary in my head for this whole thread (and other previous ones with MEL laying down the law) is basically:

A: "The FAA doesn't allow jumpers to do very much at all to rigs, and senior riggers also very little... far less than jumpers, riggers, and manufacturers commonly actually believe they can perform or actually perform in standard practice."

B: "But the FAA are idiots who don't know anything and are out of touch with the way the sport works. "

A: "That may be true, but they still make the rules."

B: "But the FAA say so many things in different sources of theirs that are contradictory, allowing all sorts of things in some of them -- so I'll take those opportunities. And the manufacturer allows certain work too."

A: "That may be true, but officially one has to take the most official documents like the CFRs/FARs and use the most restrictive requirements they list. And what the FAA says is law, not what the manufacturer says."

Then in the end everyone makes their own choice about how much to ignore the FAA. You have a lot on the line and get queasy about liability? Maybe follow their rules more closely. You can walk away from it all and think a lawsuit is unlikely or bullshit? Ignore the FAA and follow industry standards.

"Well, your honor, I followed the FAA's Rigger Manual AND what the manufacturer stated in its bulletin, AND standard industry practice. If the FAA now says differently, I don't know anything about that."

You decide if that's likely to ever happen or be a good enough defense.

Peter,
Good summary overall, but a couple of clarifications.

Quote

(and other previous ones with MEL laying down the law)

I am not "laying down the law", merely pointing it out to those that don't know it, reinforcing it to those that defy it, and educating those that wish to learn.

Most of this is towards the "30 Day Senior Rigger". That is my term for the senior rigger that just got his ticket less than 30 days ago, knows everything, can do anything (just ask him), and you can't tell him the sky is blue anymore.

With regards to your last paragraph, ignorance of the regulations or law is no excuse in any circumstance.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[pchapman 261]

masterrigger1

ignorance of the regulations or law is no excuse in any circumstance.

But life would be easier if you would stop poking into all of them!

[mark 102]

masterrigger1

I have been subpoenaed in a pending case which actually has this exact content.

"Subpoenaed" means "compelled to appear," and usually applies to _fact_ witnesses, someone who can testify to what happened in a particular case. An _expert_ witness, on the other hand, is called to express an opinion, not testify as to facts. In many jurisdictions, an expert witness's testimony cannot be compelled; that is, they cannot be subpoenaed.

Are you:
-- being subpoenaed as a fact witness? or
-- being called voluntarily as an expert witness? or
-- being subpoenaed as an expert witness?

Mark

[skytribe 16]

MEL, Do you have an FAA definition of maintain ?

I can only find one for maintenance

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Maintenance. Inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

A senior is permitted to pack and maintain except for major repairs. Is replacing a single line on a main with a factory supplied part requiring no sewing then maintenance.

With the recent rigging error thread on the UPT skyhook being hooked up wrong it shows that merely replacing a ripcord assembly could be done and effect the airworthiness of the system. Hence could it not be applied that replacing the ripcord is a major repair.

I'm finding this thread interesting in how everyone appears to have a slight skew on the interpretation but that everyone knows the FAA documents are full of contradictions and outdated references (everyone except the FAA who appear to move very slooooooowly and either don't have the expertise or don't want to make changes). I doubt the discussion will change anyones interpretation but it is interesting to hear them nonetheless.

[riggerrob 558]

.... everyone appears to have a slight skew on the interpretation but that everyone knows the FAA documents are full of contradictions and outdated references (everyone except the FAA who appear to move very slooooooowly and either don't have the expertise or don't want to make changes). ....

.................................................................................
FAA have much bigger fish to fry. Their primary goal is facilitating aerial commerce (read the airline industry).
Parachutes represent less than 1 percent of the FAA's business.
As long as parachutes do not interfere with airliners, the FAA would prefer to ignore parachutes.
Al Queda can do more damage in one minute than skydivers can do in a year.

[riggerrob 558]

.... Plenty of senior riggers have access to dz lofts with tons of machines too, so it is more than an intellectual debate, but real world application. I know a former senior riggers (deceased) who would kick out 10 linesets a week...

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

Let's try to limit this discussion to recently-licensed FAA Senior Riggers working alone, many miles from a fully-equipped loft.

[skytribe 16]

***
FAA have much bigger fish to fry. Their primary goal is facilitating aerial commerce (read the airline industry).
Parachutes represent less than 1 percent of the FAA's business.
As long as parachutes do not interfere with airliners, the FAA would prefer to ignore parachutes.
Al Queda can do more damage in one minute than skydivers can do in a year.


That may be true but there is also a parachute/skydiving industry that needs some regulation. Having so much contradictory and outdated information doesn't help anyone, except for perhaps personal injury lawyers.

[hackish 8]

riggerrob

Let's try to limit this discussion to recently-licensed FAA Senior Riggers working alone, many miles from a fully-equipped loft.

I think the FAA doesn't care how old the ticket or what tools the rigger has access to. The thread is about understanding what the letter of the law says about types of repairs.

I've been working for many years under supervision doing repairs that could be major or minor. It's time consuming and only possible through the generosity of others who are willing to donate the time to inspect/approve and offer suggestions.

-Michael

[piisfish 135]

Some will say the Y strap on a Sigma is an alteration.
I would defend myself claiming it is not an alteration but an assembly.

There is no such thing as a minor or major alteration. All alterations would involve a Master Rigger

scissors beat paper, paper beat rock, rock beat wingsuit - KarlM

[riggerrob 558]

A Senior Rigger - working under the supervision of a Master Rigger is distinct from a Senior Rigger working alone.
When we discuss Senior Rigger privileges, let's limit our comments to Senior a Riggers working alone.

[riggerrob 558]

piisfish

Some will say the Y strap on a Sigma is an alteration.
I would defend myself claiming it is not an alteration but an assembly.

There is no such thing as a minor or major alteration. All alterations would involve a Master Rigger

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

UPT says that a Senior Rigger may install a Y-strap on a Sigma student harness.

However, retro-fitting a Y-strap to a Strong tandem student harness requires plenty of machine-sewing (both 5-cord and E-thread) so Strong says that it must be done by a Master Rigger.

Remember that civilian air regulations (in most countries) loop back to "in accordance with the manufacturers' instructions."

[hackish 8]

riggerrob

A Senior Rigger - working under the supervision of a Master Rigger is distinct from a Senior Rigger working alone. When we discuss Senior Rigger privileges, let's limit our comments to Senior a Riggers working alone.

The point was more about: Whether someone has experience and access to the tools only relate to their capabilities to properly do a repair, not the legality of that repair.

-Michael