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hackish

Master or Serior ticket to make a repair?

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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?



Is it something that will be documented?
----------------------------------------------
You're not as good as you think you are. Seriously.

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I think we are talking about different things. "Lofts" no longer exist. Bear with me because I was posing a question not making a comment. My understanding of this is imperfect and I'm hoping some one can clarify this. As I understand it the FAA recognizes "Repair Facilities" I think that's the right term. It's a cite that they have certified other then the manufacturer to work on certified, TSO'd components. Example, If you want to sew on a balloon, a certified aircraft, you have to be a repair facility. If you want to work on a navigation radio or gyro then you have to be a repair facility. I know a guy that got certified to test and repair Peto static systems on aircraft. Their calibration has to be checked for the transponder. It's a real thing in FAA speak. It's a term that has a specific meaning for them.

I got the impression that the conversation with the FAA went some thing like this. Buttler is a manufacturer holding a TSO allowing them to manufacture these certified components. But there is equipment here being returned for repair. The TSO does not authorize them to repair certified components. I'm assuming they were Buttler made. Are you a "Repair Facility", note capitalization as certain terms have special meaning for the FAA. If not then how are you replacing that Velcro. The Master rigger thing seems to be a end run around the issue.

Could some one clarify how this all fits together. If a TSO lets you produce certified gear then does it matter whether or not you are a master rigger or even a senior rigger. Most are any ways but that's beside the point. Most things in the FAR's say the "Manufacturer" or a master rigger. As another example. If you build a 51% kit plain then you are the "manufacture" and you do not have to be an A+P to sign off the condition inspection, annual of the air plane. What about repairs. Is being a TSO holder authorization to perform repairs to their own TSO'd gear? It would seem from the conversation that it is not. What if they had been a Repair Facility, and there are still such things, then could they have been authorized to repair their own equipment and would it matter whether or not they were master riggers if they were an approved "Repair Technician" I think that's another term.

Can any one explain to me exactly how this works. Note that this is really more a broader FAA question and may reach beyond just arguments on AC 105.

Lee
Lee
[email protected]
www.velocitysportswear.com

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masterrigger1

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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...

MEL



A manufacturer can advise if they consider a repair to be a minor or major category of repair. Being experts in their own gear and repairs to that gear I would expect them to be qualified to make a definitive judgement.

There is a local Sr Rigger doing relines. He maintains it's a minor repair because it's a main. Based on the info posted previously I can see his point.

-Michael

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It seems that manufactures regularly define who has authorization to do what repairs on their rigs. There are many references in their manuals as to who can replace a line, who can do a patch, where they can do a patch, what kind of patch. It seems that they decide what repairs affect the airworthiness of their equipment and which are minor and major. Things like pointers and the new parachute manual are sited as references when there is no guidance from the manufacturer. They seem to be secondary not the primary rule. They seem to be taken from general practices of most manufacturers. The fact that there is argument or disagreement over them doesn't change the fact that this is what the FAA has chosen to site as standard practice in the industry to be referenced when lacking direction from the manufacturer. You dis agree with Sandy. Fine but that's just your opinion. What makes your interpolation more authoritative then his? And by the way, I'm not picking sides here. There are things in that book that I disagree with. I just wish this could come to a final ruling on this.

Oh and lets not forget SB which with out fail state who the Manufacturer authorizes to perform the SB.

Lee
Lee
[email protected]
www.velocitysportswear.com

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I don't disagree with Sandy at all. In fact I've made and done quite a number of repairs under supervision.

http://www.dropzone.com/cgi-bin/forum/gforum.cgi?do=post_attachment;postatt_id=144038;

Understanding the correct process and the technical details of the rules is important to me. I think I'm correct to summarize this by saying that a Sr. Rigger would need to check with the manufacturer if they don't exist then fall back on the FAA book or Poynter for an opinion.

-Michael

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A manufacturer can advise if they consider a repair to be a minor or major category of repair. Being experts in their own gear and repairs to that gear I would expect them to be qualified to make a definitive judgement.



Actually, they can state anything they want, but you have to realize if it is something that you can or cannot do.

Again they cannot tell you (legally) that you can do work outside of your certificate.

Here's another angle on it: (disclaimer:Just for reference)
http://www.unitedparachutetechnologies.com/PDF/Support/Product%20Service%20Bulletins/PSB_2013205.pdf

In this document, I believe there is not an exact statement as to what type of rigger can do the work or even the limitations of same said rigger.
This is because the rigs sometimes are not in our country and therefore not subject to our rules, so they simply state "rigger".

But in this country, a very liberal Senior rigger would mistakenly deduct that he or she could legally do the work.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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It seems that manufactures regularly define who has authorization to do what repairs on their rigs. There are many references in their manuals as to who can replace a line, who can do a patch, where they can do a patch, what kind of patch. It seems that they decide what repairs affect the airworthiness of their equipment and which are minor and major.



Again, They cannot legally authorize a Senior rigger to do Master Rigger work.
They may state it all day long, but they do not have the authority to "certify" you beyond your certificate privileges if you will.

Think of it this way, Cessna tells a A&P that he can do an inspection to place back in service one of their aircraft. Is he legal to do it?

That answer would be a no!
But it sure would make the aircraft more attractable to the general public would it not?

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You dis agree with Sandy. Fine but that's just your opinion.



Yes I do, but the opinions are mine and numerous other old farts to be exact.

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Oh and lets not forget SB which with out fail state who the Manufacturer authorizes to perform the SB.



We went though this with the Javelin RSL. Dig up that thread. I am tired of typing....

But to answer your statement, the senior cannot do major repairs or alterations no matter what a SB says unless they are under supervision of a qualified rigger that holds the applicable certificate.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

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A manufacturer can advise if they consider a repair to be a minor or major category of repair. Being experts in their own gear and repairs to that gear I would expect them to be qualified to make a definitive judgement.



Actually, they can state anything they want, but you have to realize if it is something that you can or cannot do.

Again they cannot tell you (legally) that you can do work outside of your certificate.

Here's another angle on it: (disclaimer:Just for reference)
http://www.unitedparachutetechnologies.com/PDF/Support/Product%20Service%20Bulletins/PSB_2013205.pdf

In this document, I believe there is not an exact statement as to what type of rigger can do the work or even the limitations of same said rigger.
This is because the rigs sometimes are not in our country and therefore not subject to our rules, so they simply state "rigger".

But in this country, a very liberal Senior rigger would mistakenly deduct that he or she could legally do the work.

MEL

negative. It States :
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Who can do this work:
Qualified Senior Rigger, Master Rigger or Foreign equivalent


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

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negative. It States :
Quote:
Who can do this work:
Qualified Senior Rigger, Master Rigger or Foreign equivalent



Thanks, I missed it.
So there you have it. Directions from a manufacturer telling a senior rigger that he can legally do master rigger work.

No where in Part 65 Rigging) allows a manufacturer to do that.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

So there you have it. Directions from a manufacturer telling a senior rigger that he can legally do master rigger work.



I dunno. The Y-strap installation looks like unthreading/re-threading friction adapter (something most of us do with chest straps pretty regularly), threading some shock cord (easier than threading an AAD cutter cable in a Mirage), and a little bit of sewing. Let's say someone really screws up the sewing. What's the worst that's likely to happen?

The manufacturer isn't saying that a senior rigger can do this master rigger work -- I agree, that would be contrary to regulation. The manufacturer is saying this is a minor repair, a judgment that is within the manufacturer's expertise to make. Since it is a minor repair, a senior rigger may do the work.

Mark

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I need to change the leg pad on my Javelin. I contact Sunpath for a new one and ask them if they would consider this a minor repair. They sell it and say it's a minor repair.

In this fictional case you have a manufacturer specifying that they consider something to be a class of repair a senior rigger could do.

You could infer that a manufacturer saying a "repair can be done by a senior rigger" does that not imply that they class it as a minor repair?

-Michael

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But is it a change? Or an addition. I don't see where the original load bearing configuration is being altered in form or function. (But I did just skim the SB and haven't done it myself)

I don't see an alteration or modification. I see an additional component being added with minor sewing to a non load bearing component needed to make it possible. In fact the sewing could be left off. Hot knife and hand tack, or not. And is only needed for type I.

Do you also consider Type II as in the SB an alteration? or an assembly? No sewing required. Just hanging things on an existing manufactured product. Certainly much less critical than reserve assembly.

Mark and I don't always agree but I'd call this senior also.

Know, there are examples that would make the point your trying to make but I think you picked the wrong one.;)

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

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[quote "masterrigger1"
I dunno. The Y-strap installation looks like unthreading/re-threading friction adapter (something most of us do with chest straps pretty regularly), threading some shock cord ..., and a little bit of sewing. Let's say someone really screws up the sewing. What's the worst that's likely to happen?

The manufacturer isn't saying that a senior rigger can do this master rigger work -- .... Since it is a minor repair, a senior rigger may do the work.

Mark



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

Maybe installing a Y-strap on a Sigma harness is "a minor alteration" done by a Senior Rigger, but installing the same Y-strap on a Strong Tandem Student harness requires popping a bunch of stitching on the leg-pads and back-pad and sewing (with 5 cord) the new Y-strap to the leg straps and shoulder straps. Then you re-close the leg-pads and back-pad, etc.
I up-dated 20-some-odd Strong Student harnesses the winter they announced that update. My Class 7 sewing machine got lots of exercise that winter, what with frayed Javelin MLWs, etc.
Since the Strong Y-strap update requires 5-cord, it counts as a major repair.
I count most harness sewing as major repairs.

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masterrigger1

Any change to the original manufactured configuration is considered an alteration by the FAA's own definition.



14 CFR Part 1, Definitions and Abbreviations, does not include a definition of "alteration." Part 43 applies to aircraft, not parachutes. Parts 65, 91, and 105 do not include a definition of "alteration." Is there another regulation that applies?

AC 105-2E has a definition of alteration includes the statement that changes resulting in an approved configuration are major or minor repairs, not alterations. I'm going to go out on a limb here and guess that having a Y-strap on a tandem passenger harness is an approved configuration and that adding a Y-strap to a harness would therefore be considered a repair by UPT and UPT's FAA ACO.

Mark

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Mark,
From 8300.16
Appendix A

Alter. To change or modify.

With the combining of the Orders into 8100,8200,8300 and etc.
It gets harder to find things anymore.

Also, with the standardization of the Orders, all definitions are used across the board. This means aircraft, power plants and appliances are using the same definitions.

In fact, the aircraft boys are now using the definition of supervision found in Part 105 (parachuting) for their legal interpretation.

From Legal Clarification dated Sept.24,2001,page 8
Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications—

(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.

Major repair means a repair:

(1) That, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.




Another reference:
http://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/agamcmmt1-010594.pdf

Order 8300.16
http://www.faa.gov/documentLibrary/media/Order/8300_16.pdf


Also note that the ASI is the person that is tasked with making the determinations (or supposed to be) in regard to major or minor repairs; not the Certificate Holder.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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***
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.

MEL

My take away from this thread is that it is scary. Not scary enough that we have so much litigation in the USA, but we also have a very outspoken individual who has extremely strong OPINIONS on how to interpret FAA documents and Manufacturing documents, who has for years posted to DZ.com and other places his OPINIONs as FACTS, without acknowledging other equally qualified rigger's alternative interpretations of the same documents as being valid OPINIONs.

Now the same individual will be testifying presumably against another skydiver, and I have no confidence this individual will tell the judge and jury that other qualified and competent individuals have interpreted the same documents differently, and therefore there is ambiguity in the industry.

I sure hope multiple witnesses are called.... I also sure hope this witness, as an individual, does not go on the stand proclaiming Poynter and the official FAA adopted handbook, manufacturing SBs, and other documents are wrong, as he has here... The only thing we have as riggers are the manuals and handbooks to protect us. We need to have the right to tell a jury "I followed page 27 of a manual published by the FAA that was current at the time" without the fear a fellow skydiver will testify the manual we are following is extremely flawed and riggers who follow it are failing. In this same thread UPT and Poynter are both wrong too in this person's OPINION, so we have nothing to protect us. And it is not just this issue where this will hurt the industry, say a Master rigger followed the book and the harness failed due to an extremely hard opening, they now lost the credibility of the book they followed by case precedent or fear of testimony from fellow master riggers.

The FAA regulations are short, broad, sometimes conflicting or ambitious guidelines. Without the credibility of specific documents like the FAA handbook, poynter, or manufacturing SB guidance, we riggers will always be f%&+3d in a lawsuit.

I believe the only answer this person or any rigger should give in a court case is: "My opinion does not matter. The FAA's documents, manuals and documents by the manufacturers, PIA, and industry recognized handbooks are all valid sources of information for riggers to follow, and it is not my place, nor am I qualified to interpret the language in those documents. That is something for lawyers who have years of training in contract and regulatory language. If the document says an individual has the right to do it, while I might disagree, who am I to say the FAA is wrong? And didn't the waiver the person signed cover this unfortunate accident?"

But I digress. Let the lawyers shut down skydiving or over regulate it until no one can keep a dz open. Outspoken riggers testifying against fellow skydivers then can laugh all the way to the (bank)ruptcy.

Everything said above is opinion.

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My take away from this thread is that it is scary. Not scary enough that we have so much litigation in the USA, but we also have a very outspoken individual who has extremely strong OPINIONS on how to interpret FAA documents and Manufacturing documents, who has for years posted to DZ.com and other places his OPINIONs as FACTS, without acknowledging other equally qualified rigger's alternative interpretations of the same documents as being valid OPTIONs.




It should be scary to everyone.

My strong opinions (which mostly you are referring to is the 65.111 Interpretation) which went on for over 7 years. I believe that my opinions actually turned into facts in that case. Did it not?
The reason that it did is that other equally qualified riggers with the same opinion, pushed for a clarification, just not on this forum or your earshot.

There are other people in the background just so you know,


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Now the same individual will be testifying presumably against another skydiver, and I have no confidence this individual will tell the judge and jury that other qualified and competent individuals have interpreted the same documents differently, and therefore there is ambiguity in the industry.



Since I cannot comment of the context, I can comment on the fact that will tell what I believe the truth is.

Being a skydiver has nothing to do with it; being a rigger does.


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The FAA regulations are short, broad, sometimes conflicting or ambitious guidelines. Without the credibility of specific documents like the FAA handbook, poynter, or manufacturing SB guidance, we riggers will always be f%&+3d in a lawsuit.



Well people like you need to review the regs and also review what is being written in the newer books because they do not match sometimes. It is easy for someone to accept a more liberal view of the regs. It is human nature,

Also the "books" are also someone else's opinion, so keep that in mind.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1


just not on this forum or your earshot.

There are other people in the background just so you know,



For the record, I rarely read these forums anymore, but I am staying current in the industry...

Are you suggesting there is a secret underground group of riggers who are lobbying for change or promoting changes in regulations that operate in the background that I don't have access to by reading PIA meeting minutes or talking to those who had the ability to attend PIA seminars or committee meetings, and by reading FAA, USPA, and other publicly available documents. :P That is a rhetorical question, and I am also guilty as charged as I have talked to some of the same FAA individuals via phone and email that you have in the past.

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Being a skydiver has nothing to do with it; being a rigger does.



I absolutely agree. When holding a rigger's ticket, you are held to a higher standard. But skydivers are our customers, and some of us love skydiving more than rigging.

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Well people like you need to review the regs and also review what is being written in the newer books because they do not match sometimes. It is easy for someone to accept a more liberal view of the regs.



I honestly don't know who "people like me are"? Clearly I am thus in a different class than you, because you did not say, "people like us".

Why am I any different than you? Am I less educated? Less caring? We have only met once in person at PIA, so I don't know who you are to judge me. Is it because over the years we have had different opinions, and because you believe so strongly yours are right, that I am somehow in a class of "people like you?".

I take rigging extremely seriously. I perform both parachute rigging, and rigging of theatrical trusses and equipment in concerts and theaters. I also made mistakes in both environments that could have killed good friends, and I have caught mistakes that have saved lives (a reserve that would have fallen off of a riser on opening).

I hope "people like you" will never be called to testify against "people like me" when we follow the written industry protocols, but some lawyer is able to spin that the protocol is invalid because it is in conflict with another written protocol, especially if my actions had nothing to do with the accident, like the rather infamous case where Poynter and another skydiver both were expert witnesses in a case where a lady stalled a reserve, known to fly poorly (both the skydiver and reserve brand) and sued the container manufacturer.

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***Replacing 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.

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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.

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How 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.

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What 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.

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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?



Imagine yourself in court with Dan Poynter. Now imagine he's sitting at the other table.

Mark

Mark, I have over the years learned to respect your rational thought and fair interpretation of industry standard protocols. I do agree with what you say above. Thanks for posting it.

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masterrigger1

From 8300.16 . . .



8300.16 deals with aircraft major repair and major alteration approval. See the decision tree in Figure 3-1, which references Parts 21 and 43, both aircraft regulations.


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From Legal Clarification dated Sept.24,2001,page 8


Inadequate citation. What legal clarification?

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From the reference above: ". . .issues involve mechanic certification and approved training schools outlined in parts 65 and 147 and the maintenance standards for parts 23, 25, 27, 29, 31, 33, and 35 aircraft, engines, propellers, and their component parts and parallel provisions in parts 21, 43, 91, 121, 125, 127, 129, 133, 135, and 137 of the Federal Aviation Regulations (FAR)." Still nothing for parachutes.

Finally, with respect to the attachment regarding Mr. Collins' request for legal interpretation, it refers to AC 43-13-2B, which contains some specific FAA-approved alteration procedures for aircraft. Not parachutes.

Do you have any other sources for definitions of "alteration" as it pertains to parachutes?

Mark

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I honestly don't know who "people like me are"? Clearly I am thus in a different class than you, because you did not say, "people like us".



It means basically the general public.
Yes, I think I am different,not better,just different in the fact that I own and have read CAA Regulations and FAA regulations dated back from 1933 to present. And when you put all the pieces of the puzzles together it makes a lot more sense.

I am saying people like you probably do not have these references at hand.

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I hope "people like you" will never be called to testify against "people like me" when we follow the written industry protocols, but some lawyer is able to spin that the protocol is invalid because it is in conflict with another written protocol, especially if my actions had nothing to do with the accident,



I hope not either.
But if you follow the regs (and not some fairy tale AC) and have conservative instead of possible liberal views of the regs you would be just fine.

....or better yet just get a master's certificate and problem solved.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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