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parafredo

Making parts

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This thread:

http://www.dropzone.com/cgi-bin/forum/gforum.cgi?post=4703903;sb=post_latest_reply;so=ASC;forum_view=forum_view_collapsed;;page=unread#unread

is in fact about what is permitted or not under the different tickets. I still have to spend some time reviewing what was said about manufacturing parts but even that didn't seem to have a solid answer. I missed the A1 course this fall so I can't comment on what A1's should be permitted to do.

-Michael

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Maybe it's the local culture.

There often haven't been Rigger B's or Master riggers around where I am in southern Ontario, even though it is a reasonably big Canadian skydiving market. Every rigger just sews whatever he wants, and uses his judgment as to what he does, apprenticing and practicing as necessary with whatever machinery is on hand. If everyone followed the rules all of a sudden, nothing would get done except in a very few limited places.

Of course we don't have TSO's in Canada so you're not breaking any gov't rules, only exceeding what one is allowed by one's CSPA rigger rating if working on gear. And do CSPA rules on not sewing by a Rigger A even apply if building stuff? After all, we don't have rules on main canopies like the FAA has in the US. So couldn't a non-rigger build parts, because there are no federal laws here? So it is almost like one can do more with no rigger rating, because a non-rigger hasn't gotten any rating that restricts him to certain tasks.

The DZ where I worked after getting my rigger rating has a few sewing machines, and there's almost never been a Rigger B around in 25 years. The DZO didn't have a Rigger B, I didn't have one, but the current guys have US Senior ratings.

So they're allowed to go sew stuff after doing a single course, something not possible with the Canadian system. Mind you the US certified riggers are supposed to follow FAA rules and manufacturer directives, so if following the rules properly (as Masterrigger1/MEL reminds us), then there's a lot that Senior riggers aren't allowed to do even on mains.

In a way it is handy that there is much less guidance for Canadian riggers. Gives us the flexibility to do more of whatever we believe is right, and ignore anything stupid to come from manufacturers, based on our best rigging judgement. (Naturally there are areas where custom and rules are stricter -- eg, AAD maintenance.)

Heck I've done a couple sewing repairs on reserves with a Rigger A rating, because if I didn't do it, it wasn't going to get done. It's not like I was taking food from the mouth of a Rigger B nearby.

One of the best local riggers now has a Rigger B and builds containers, but when he was fresh off the boat (so to speak) and rigging, he was probably doing so with only a Cuban rigger's rating. For a long time he was building all sorts of stuff with his Rigger A rating, so he probably had no problems when he sent in his materials for the Rigger B and got that.

So whether the local role models were someone like him, or a local DZ, the attitude has long been to just do things if one thinks one can do them safely. As applies to much of skydiving. If one can also make a better product and/or cheaper, then one gets more business.

It does mean, for better or worse, there hasn't been a lot of emphasis on upgrading ratings. (With the Canadian A1 and A2 now, the system if more professional in some ways, but a lot more expensive and just pushing people to get American ratings.)

I haven't personally seen many problems with equipment produced by local riggers whatever their status. There are always some items that aren't that great or don't work so well, but there's no rule on not having crappy old gear from manufacturers that doesn't work well either.

It would be interesting to get a list of local Rigger B's and Master ratings, and see who is actually still around and active.

I don't know how the situation is in Quebec for riggers...

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parafredo

I do have a concern about this issue. I see on the field that some senior riggers and A1 canadian riggers are starting to make spare parts as: main d-bags, pilot chute, briddles, cutaways.... Is it me or I find that this is going too far !!!




If you have some concerns, uneasiness or worries , at this time, concerning Canadian senior riggers, in the field, A1 riggers or whatever they are called nowadays, you must have seen some of them doing or repairing some skydiving parts, being somewhat unusual or odd ...in various regions of the province or elsewhere...
....would you please, elaborate on the subject, maybe giving some examples !
In many years, I have seen a few riggers doing new stuff and repair works and even though its not, sometimes, at the level in quality of the original manufacturers, its seems quite fine !
Naturally, I do not know what is the quality of work in the West or in the East of the country !
I assume they know what they are doing !

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parafredo

I do have a concern about this issue. I see on the field that some senior riggers and A1 canadian riggers are starting to make spare parts as: main d-bags, pilot chute, briddles, cutaways.... Is it me or I find that this is going too far !!!



When I was still in the game (sr rigger only) I did a lot of this... as my sewing skills got better I said to myself "Assuming I can duplicate this so the ending dimensions and materials are 1:1, I can make that!!!"

"That" included making the odd D-Bag, replacing lines on mains, replacing bridles on non-collapsible PC (it's just bloody square weave), and ultimately making collapsible PCs.

My theory was that if I can make some money at it and it can be cut-away, go for it. So I never messed with reserve components like cutaway handles, reserve ripcords, reserve line replacements, reserve DBags, etc.

Granted a screwed up collapsible PC posed some risk in the "can cut it away" philosophy... but I was confident in my ability to duplicate a PC more or less exactly (I used a Sunshine Factory PC as my model, those were built like brick sh*t houses). They sure as hell were better then some of the PCs that came from major manufacturers for awhile (cough Talon cough).

__________________________________________________
What would Vic Mackey do?

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I agree with what you're saying. I inspected one of the rigs made by the guy you mentioned and I was so impressed with the construction that I bought one.

There are a few parts that worry me. First is without any rules or framework you have no idea how well made some piece is. Is that proper tape or just some chinese crap for making tents?

At least with a requirement of a rating you push the individual to attend the necessary education and be vetted by the examples of work they produce to pass the course.

The second issue is liability. The second they step outside what the rules say they're exposed up bigtime. Some riser you make fails you can imagine what questions you'd be asked in court. With no right to make a part imagine defending it in course even perfectly constructed. Make some Ty17 risers. Then the RSL side breaks on a hard opening and the guy goes in. Negligence causing death does carry prison time.

Up here in Quebec there is a looser culture. I'm seen as the tete carre for wanting to follow the rules and even pack according to manufacturer instructions.

It's not actually that hard to find an established rigger B or master rigger who is willing to supervise some work. If the objective is to work within your ticket then it can still be done.

-Michael

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It's not actually that hard to find an established rigger B or master rigger who is willing to supervise some work. If the objective is to work within your ticket then it can still be done.



Unless you live in Winnipeg!
Always remember the brave children who died defending your right to bear arms. Freedom is not free.

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hackish

With no right to make a part . . .



Read by itself, this sounds as through one needs permission to make non-TSO'd components. In the U.S. (and Canada, too, I think), there are no restrictions on who may manufacture non-TSO'd components or what materials they might use.

Mark

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***With no right to make a part . . .



Read by itself, this sounds as through one needs permission to make non-TSO'd components. In the U.S. (and Canada, too, I think), there are no restrictions on who may manufacture non-TSO'd components or what materials they might use.

You have to take it in the context it was written.

As per CSPA, a Canadian Rigger A or A1 is not permitted to make these parts. TSO isn't particularly relevant as it is not a distinction as in the USA. TC says to follow a professional org. For the most part it's CSPA.

It's been years since I looked at the exact fine print wording (they wanted to pass a that would have really caused issues!) I can't recall much of a leg you could stand on.

-Michael

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hackish

As per CSPA, a Canadian Rigger A or A1 is not permitted to make these parts.



But the thing is, one can just lay aside one's ratings and sew as a member of the public, on a main, reserve, or harness.

Transport Canada has no rules on what gear to use except for official demos, where it is basically TSO gear. (One can legally jump uncertified BASE gear from airplanes in Canada.) If jumping at a CSPA DZ under CSPA rules, CSPA rules say you need to have a reserve parachute inspected & packed by a Canadian or US rigger within 180 days. (USPA DZ's in Canada will have similar rules, and CAPS too if any still exist.)

There are otherwise no rules about TSOs, manufacturing, manufacturers, etc. You just need a rigger to believe the rig and reserve are safe enough to jump that they'll pack it.

It's always possible you can find some rules I've missed and I'm fine with that. It can be tough to find how they all fit together.


==========
Background that you would know. By PIM1 2014, rigger privileges include beyond the packing stuff:

Rigger A - remove and replace component parts; make minor hand repairs

Rigger A1 (only existed in last couple years) - make basic patches, change lines, "manufacture simple components"

Rigger A2 (only existed in last couple years) - complex patching, simple harness repairs, "manufacture components"

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... one can just lay aside one's ratings and sew as a member of the public, on a main, reserve, or harness .

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

Sorry, but a licensed/certified rigger is not allowed to "lay aside a rating." Any time a licensed rigger does business, the onus is always on the rigger to ensure that the transaction is legal, honest and airworthy.

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riggerrob

You cannot legally jump (reserve-less) BASE gear out of an airplane at a CSPA-affiliated DZ.



In Canada in general you can jump such gear. Your local CSPA DZ may not choose to do "non CSPA" jumps, and probably won't. But they could decide to cater to the BASE crowd and send up a load to 500' if they so chose, stating that it isn't a CSPA load.

Unless there's some hitch I haven't heard of, which is possible. E.g,
a) the DZ they've signed something saying all jumps they do must be CSPA style ones. (Well then they just rent the plane out to someone else so the DZ isn't the entity offering the jumps)
b) if somehow their Transport Canada Operator Certificate also had something in it about following CSPA rules.
c) Or if some Memorandum of Understanding with how they integrate with air traffic control is similar.
d) Or I don't know if CSPA members somehow agree to always follow CSPA rules, even when not at CSPA DZs.

So there are some interesting things that could be looked up to see how it really works out. But that's a whole other topic.


As for "laying aside a rating", why would a member of the public have more rights than a rigger? One's aunt is legally allowed to sew up D-bags (or a whole rig) but the rigger A can't?

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As for "laying aside a rating", why would a member of the public have more rights than a rigger? One's aunt is legally allowed to sew up D-bags (or a whole rig) but the rigger A can't?



Yes, you could legally do that and tell yourself you have "layed your rating aside". But the sanction that you risk is that CSPA could revoke your rating. Not an insignificant action if you are wanting to sign packing cards.
Always remember the brave children who died defending your right to bear arms. Freedom is not free.

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gowlerk

Quote

As for "laying aside a rating", why would a member of the public have more rights than a rigger? One's aunt is legally allowed to sew up D-bags (or a whole rig) but the rigger A can't?



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

Yes, you could legally do that and tell yourself you have "layed your rating aside". But the sanction that you risk is that CSPA could revoke your rating. Not an insignificant action if you are wanting to sign packing cards.



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

I am siding with Gowlerk on this debate.
I don't know who gave Mr. Chapman's aunt the god-given right to sew parachutes?????????

If anyone dies while jumping one of her parachutes, the coroner will ask her plenty of embarrassing questions. Police, courts and coroners treat all accidental deaths as criminal homicides.
If anyone gets hurt - using home-made gear, then his heirs might drag the aunt in to court.
A CSPA-certified rigger cannot plead "ignorance of the law."

If a CSPA-certified rigger "exceeds his certificate" he stands alone in court. A judge might ask if the sloppy sewer ignored " best business practices." Certified riggers are bound to conduct their business in accordance with "best business practices." BBP including sewing stitch patterns that resemble factory standards, the same MIL SPEC/PIA SPEC materials and the same finished dimensions as parachutes manufactured in factories.
IOW home-made parachutes are only kosher if the materials and workmanship resemble factory products at arm's length. Most riggers don't achieve that quality of workmanship until they have completed as much training as a CSPA Rigger C2.

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riggerrob

I don't know who gave Mr. Chapman's aunt the god-given right to sew parachutes?????????



Is there something in the regs that specifically says that parachute components can ONLY be sewn by licensed FAA riggers?

riggerrob

parachutes manufactured in factories.



Don't those factories which make all of our parachutes employ seamstresses who aren't riggers?

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TomWatson

Is there something in the regs that specifically says that parachute components can ONLY be sewn by licensed FAA riggers?



There are significant US & Canadian differences.

We don't have the TSO system in Canada, and our parachuting regulations are mainly from the voluntary organization CSPA and only a tiny bit from the gov't (Transport Canada) -- not like the US where a lot of regs are from the FAA itself, when it comes to gear & rigging.

So under the FAA regs, only a Senior or Master rigger might be able to legally do things to even a main parachute.

(Jumpers themselves can do some basic assembly but not modifications. There are other threads debating US rigging issues, as in the States it is quite normal for riggers and jumpers to go beyond what they are legally allowed to do.)

I guess the seamstress thing is covered by the factory being under the supervision of the appropriate rigger (whether or not they actually inspect every sewn seam!)

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In the US the main parachute must be packed by the person making the jump, a rigger, or a person supervised by a rigger. Right? So it stands to reason that a non-rigger should be able to make his own main parachute too. And in fact some people have. As long as it's the main parachute, and not the reserve, I don't think that's any kind of violation.

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Don't those factories which make all of our parachutes employ seamstresses who aren't riggers?

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


Yes, but all their sewing has to pass an inspector before it leaves the factory. Some factories insist on inspecting a harness/container 4 or 5 times along the production line. The first inspection is often at the cutting table to ensure that the sizes and colours match the order form. Some complex pieces (e.g. mid flaps with fancy coloured stripes ) are inspected before they are sewn to the next piece. If a stitch pattern will be hidden in the final product (e.g. structural back straps) they need a "closure inspection" before the chute can continue along the production line. The inspector must initial or stamp the production paperwork before the piece can continue along the production line.
The final inspector compares the order form with the final product, colour(s), size, length of harness, symmetry of harness, correct number of rings, correct size of rings, 5-cord in all the major harness junctions, grommets in all the flaps, bar-tacks in all the heavily-loaded corners, etc.
Inspection criteria are written into the quality control manual that is part of FAA approval to manufacture parachutes under TSO C22. Inspection criteria are often nailed to the wall above inspection stations. Each factory designates a chief inspector who can then designate his responsibility to a Senior rigger or highly-experienced sewer. Production parachute inspectors need keen eyesight, attention to detail and an intimate knowledge of sewing techniques.
That is what is often lacking with home-made parachutes. Home-made parachutes also lack the "second set of eyeballs" which are virtual in the flying business.

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jonstark

You can jump bedsheets and kite string for a main! Why would working on it require a riggers ticket?



Because it's required by FAR 65.111.

On the other hand, there is no 51% rule as there is for experimental aircraft. If you want to manufacture from subassemblies, there is no prohibition.

Mark

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***You can jump bedsheets and kite string for a main! Why would working on it require a riggers ticket?



Because it's required by FAR 65.111.


§ 65.111 Certificate required.

(a) No person may pack, maintain, or alter any personnel-carrying parachute intended for emergency use in connection with civil aircraft of the United States (including the reserve parachute of a dual parachute system to be used for intentional parachute jumping) unless that person holds an appropriate current certificate and type rating issued under this subpart and complies with §§ 65.127 through 65.133.


Note that part (a) applies only to reserve or emergency parachutes.


(b) No person may pack 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;
(2) Is under the supervision of a current certificated parachute rigger;
(3) Is the person making the next parachute jump with that parachute in accordance with § 105.43(a) of this chapter; or
(4) Is the parachutist in command making the next parachute jump with that parachute in a tandem parachute operation conducted under § 105.45(b)(1) of this chapter.


Part (b) applies to main parachutes, and (3) covers the person making the jump, whether they are a rigger or not.


(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

And part (c) talks about "maintain or alter", but that doesn't seem to include making one from scratch. Maintain or alter implies that the parachute already exists from some other source.

So those folks out there making their own parachutes, are they really violating the regs?

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So those folks out there making their own parachutes, are they really violating the regs?
.......................................................................................

Less than 1 percent of skydivers possess the machines, skills or patience to sew their own parachutes.
I sewed and jumped (hundreds of times) a pair of kit parachutes during the 1980s.
How many have you made?

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