kkeenan 13 #1 April 29, 2015 Wondering about thoughts on this: How much rebuilding of a tandem harness can a Master Rigger legally do ? If a harness is "repaired", retaining nothing of the original except the hardware and the label, and the work is done to the manufacturer's spec., is that allowable ? Or is there a limit as to what can be done by an entity other than the TSO holder ? I know that the regs on this are somewhat loosely written, so it may be subject to interpretation. I pick this hypothetical extreme case just out of curiosity. Kevin K._____________________________________ Dude, you are so awesome... Can I be on your ash jump ? Quote Share this post Link to post Share on other sites
RiggerLee 61 #2 April 29, 2015 It's not as hypothetical as you might think. Their was actually a case of some one rebuilding a complete tandem rig retaining nothing more then the label. No shit the guy did it. Apparently his sewing was just a little off because it was at some point spotted. It raises interesting questions. Their is actually a precedent. You can "salvage" an aircraft out of a lake with a pair of tin snips by retrieving the plate on the side of it and then repairing every other part. Their are some paper work loops to jump through in how you repair it but the FAA is aware and has given it's blessing. It is done. This is not hypothetical. So in theory you could perform a major repair on every part except the label. People do perform major repairs, ex. rebuilding one whole side of the main lift web. And it has at times gone wrong. For example some one was talking at PIA about a master rigger that did such a repair with 5 cord but he used an old spool that had been setting on a shelf in the sun light from a window. One of the junctions failed and every one freaked out. The manufacturer freaked thinking that they had a problem with hundreds of rigs that had been sewn with that lot of 5 cord till they realized that it had been repaired in the field. Their are some subtle issues with actually doing these things right. How long have you been using that spool of thread? I sew a lot and I do go through spools but a 16 oz. will last most riggers a life time, and that's not really a good thing. Rebuilding rigs. Yah their are people that could do it. I could do it. In fact I'd bet money that the actual manufacturer would not be able to spot it once I was done. I guess It's a good thing I never got my masters ticket. But is it a good idea? The extension of that is, Should their be limits to a major repair? At some level should a master rigger need an authorization from a manufacturer to perform a certain level of repair. At the least should the manufacturer be apprised of the repair. I mean in theory the repair should be documented on the packing data card but what if it is separated or goes with the canopy if the gear is sold. In theory for the rig to be airworthy it must be signed off again by a master rigger but if it's even half way well done it should not be easy to spot it. What is the line between a major repair and an alteration. Their is data stored on every single rig. Every order form, every materials tracking sheet, every purchase order. If a rig is repaired and a peace of hard ware is changed out or a junction is resewn has the rig been altered? As in the example it is no longer sewn with 5 cord from that lot as specified in the materials tracking in the TSO paperwork. I could argue that that is an alteration of the rig and requires authorization from the manufacturer. At the very least they should be aware of it and I could argue that it should be added to that rigs file. We re size main lift webs all the time. Isn't that an alteration? It no longer matches the date in the file from it's construction. I could argue that you should call the manufacturer and receive an authorization to allow you to do it. They should send you a data packet with the specs on how it should be sewn and what materials should be used. A form to send back with the new finished measurements and any material tracking data that you have on the repair. And that should be added to the permanent file of the rig. I'm not a big fan of regulation but their is a logic it. So kick that around for a bit. I'm board. Entertain me. LeeLee [email protected] www.velocitysportswear.com Quote Share this post Link to post Share on other sites
riggerrob 558 #3 April 29, 2015 RiggerLeeIt's not as hypothetical as you might think. Their was actually a case of some one rebuilding a complete tandem rig retaining nothing more then the label. No shit the guy did it. Apparently his sewing was just a little off because it was at some point spotted. ..... Lee" ................................................................................................ The rigger in question was Ray Ferrel (sp?) from Action Air in Northern California. He completely rebuild a Vector Tandem. His work was only spotted when the rig returned to the Relative Workshop and they noticed that it was a different colour from production tracking sheets. I draw the line at cost. If I cannot do the repair for about the same cost as the factory, then I tell the customer to send it back to the factory or buy a new one. Sometimes shipping is more expensive than the repair. Because I live in Canada, it might be more cost effective for me to repair a tandem rig than shipping it back to Florida or Germany for repair. Also consider the complexity of a repair. If the repair requires specialized patterns or sewing machines fancier than mine, then I tell customers to return the rig to the factory for repairs. Quote Share this post Link to post Share on other sites
JerryBaumchen 1,061 #4 April 29, 2015 Hi Lee, Quotespecified in the materials tracking in the TSO paperwork. Parachute equipment today ( in the USA ) is being built to four different versions of TSO C23(x). I know of absolutely nothing in any of those four versions of the TSO that requires the 'tracking' of materials used in construction. Some mfrs may have included the tracking of materials in their Quality Program but it is not a TSO req'ment. And, if someone finds out differently, I will happily be corrected. Jerry Baumchen PS) And IMO, the approval of the Quality Program, by the FAA, is as subjective as 'So what do you think of that blond over there?' Quote Share this post Link to post Share on other sites
RiggerLee 61 #5 April 29, 2015 I miss spoke. TSO being the wrong word. As I see the whole point of the issuing of a TSO is the QC program. Yes, it's an approval of a design but that seems small in comparison to the approval of the QC program. I can't imagine materials tracking not being a part of that. I can tell you that every roll of webbing and tape was stamped. Every drawer of hardware had a card in it. Every material was traced back through purches orders to lots from the supplier. And every rig built carried paper work with tracking for every part that went into it. I watched stanford going around filling out which roll of webbing the type 8 came from. Which roll the type 7 was from. Which batch of hard ware the three rings were from. Every roll of binding tape was stamped. And every spool of thread had a sticker on the bottom of it. Many of a time I'd be sewing and he would walk by with a clip board and turn the spool over and note the information down for that rig. Maybe he was just anal. May be that's the way his QC program was approved. But all of that data was kept for every rig, forever. That was my experience working for him as a young dumb slave. If your not tracking that information then what's the whole point of holding a TSO? I always thought that that was the basis for the issuance of the TSO. To approve the design and to insure the continuation of the production of it as it was issued and to create a means for tracking the materials in the event of a failure. LeeLee [email protected] www.velocitysportswear.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #6 April 29, 2015 Quote Parachute equipment today ( in the USA ) is being built to four different versions of TSO C23(x). I know of absolutely nothing in any of those four versions of the TSO that requires the 'tracking' of materials used in construction. Some mfrs may have included the tracking of materials in their Quality Program but it is not a TSO req'ment. And, if someone finds out differently, I will happily be corrected. Jerry, I know for sure that when Part 149 was mandatory, so was the material traceability. For those who do not know this, Part 149 was "Certified Parachute Lofts". Back in the day, all rigging was supposed to be done in these lofts as per regulations. Part 149 was dismantled in 1993 I think... So the TSO did not require traceability, Part 149 did. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
JerryBaumchen 1,061 #7 April 29, 2015 Hi Lee, Quote I always thought that that was the basis for the issuance of the TSO. To approve the design and to insure the continuation of the production of it as it was issued and to create a means for tracking the materials in the event of a failure. Again, there is no tracking of materials req'd. As to just how each company wants to take care of their materials; well, that is all about how they write their Quality Program Manual. It is usually a trade-off; risk vs costs, in a nutshell. When I worked for the federal gov't. in Contract Management I worked with literally 100's of companies where we had very detailed Quality Program req'ments ( these companies were located in N. America, S. America, Asia & Europe ). There are many, many ways to get from A to B; almost all will eventually get you to B. Jerry Baumchen PS) A little story about risk vs costs. I worked with a company called Flint Steel in Tulsa, OK. They did no in-process inspections, only a final inspection of all atributes just prior to the coating process. This worked for them. Then there was Bethlehem Steel in Pinole Point, CA. They did an inspection after each process. There the final inspection was litle more than a check-off of the previous paperwork. This worked for them. Quote Share this post Link to post Share on other sites
JerryBaumchen 1,061 #8 April 29, 2015 Hi Mark, QuoteI know for sure that when Part 149 was mandatory, so was the material traceability. For those who do not know this, Part 149 was "Certified Parachute Lofts". However, I am not talking about material certifications. I am talking about the tracking of materials into the final product. I have material certifications going back to 1979 still on file. I have yet to discard even one. Jerry Baumchen Quote Share this post Link to post Share on other sites
mark 102 #9 April 30, 2015 masterrigger1When Part 149 was mandatory, so was the material traceability. For those who do not know this, Part 149 was "Certified Parachute Lofts". Back in the day, all rigging was supposed to be done in these lofts as per regulations. Part 149 was dismantled in 1993 I think... So the TSO did not require traceability, Part 149 did. Part 149 is quoted in full in Poynter Volume 1. It did not require material traceability, only materials of proper strength and quality -- the same standard as required riggers working outside a Part 149 loft, and the same standard as we are held to today. How that could have been assured for a Part 149 loft was a matter between the loft certificate holder and his or her supervising FAA office. Back in the day, almost all riggers legally worked outside a Part 149 loft. Poynter Volume 1, page 31, paragraph 3.300: "The [loft] certificate is of questionable value since it increases duties and responsibilities while it does not increase rights or privileges. . . In the parachute loft, the master rigger must sign off all major repairs. This he must do whether or not the loft has an FAA rating." Mark Quote Share this post Link to post Share on other sites
masterrigger1 2 #10 April 30, 2015 Quote It did not require material traceability, only materials of proper strength and quality -- the same standard as required riggers working outside a Part 149 loft, and the same standard as we are held to today. How that could have been assured for a Part 149 loft was a matter between the loft certificate holder and his or her supervising FAA office. Determining proper strength and quality is easy. You simply hold onto the certification that comes with every order of material. Jerry just stated that he does this also. The standard of receiving a cert for materials has been going on before you and I was born. Now if you are buying from an unreliable source like from EBay, where you probably would not get a certification, that would change things somewhat! Quote Back in the day, almost all riggers legally worked outside a Part 149 loft. Poynter Volume 1, page 31, paragraph 3.300: "The [loft] certificate is of questionable value since it increases duties and responsibilities while it does not increase rights or privileges. . . In the parachute loft, the master rigger must sign off all major repairs. This he must do whether or not the loft has an FAA rating." Back in the day, a lot of people built rigs in their basement and thought that was legal when it was not. Most rigging work was done in a 149 loft, all master rigger work HAD to be done in a 149 loft until about 1985. As far as Poynter's quote; it is/was his opinion and one I do not mirror. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
mark 102 #11 April 30, 2015 masterrigger1Most rigging work was done in a 149 loft, all master rigger work HAD to be done in a 149 loft until about 1985. I think you might be misremembering. There were never more than a handful of 149 lofts. Most rigging work was done the way it still is, in basements, garages, and in or near a dz packing area. There has never been a requirement for master rigger work to be done in a 149 loft. If there had been, it would have been mentioned in 65.127. Mark Quote Share this post Link to post Share on other sites
kkeenan 13 #12 April 30, 2015 riggerrob***It's not as hypothetical as you might think. Their was actually a case of some one rebuilding a complete tandem rig retaining nothing more then the label. No shit the guy did it. Apparently his sewing was just a little off because it was at some point spotted. ..... Lee" ................................................................................................ The rigger in question was (name deleted). He completely rebuild a Vector Tandem. His work was only spotted when the rig returned to the Relative Workshop and they noticed that it was a different colour from production tracking sheets. In the example above, was this technically legal? Even if all materials used were quality-documented and the workmanship were factory-standard, how could this be shown on the product itself? If the only label used was the original, it would look like it (the reproduced assembly) was from the manufacturer. I realize that this is regulatory hair-splitting, but could it be technically legal ? Kevin K. Quote Share this post Link to post Share on other sites
JerryBaumchen 1,061 #13 April 30, 2015 Hi Kevin, QuoteI realize that this is regulatory hair-splitting, but could it be technically legal ? Obviously, the final arbiter would be the FAA. However, IMO it would be technically legal. However, IMO ( again ) I do not think it should be legal. I think that there should be limits on going to this extent. One could merely buy a bunch of worn out rigs &, in essence, become a mfr. Just my $0.02, Jerry Baumchen PS) Edit to add: Many canopy mfrs have limits on how many patches, where, etc. Maybe there should be some limits on rebuilding a harness and/or a container. Hmmmmm! Quote Share this post Link to post Share on other sites
riggerrob 558 #14 May 1, 2015 Agreeing with Jerry ..... "Repairs" should be done so neatly that a Senior Rigger cannot distinguish them from factory sewing. Changing the stitch pattern is a no-no. Changing the colour is definitely a no-no. If a repair changes the configuration ( e.g. adding hip rings) it voids the TSO. Quote Share this post Link to post Share on other sites
masterrigger1 2 #15 May 3, 2015 Quote I think you might be misremembering. There were never more than a handful of 149 lofts. Most rigging work was done the way it still is, in basements, garages, and in or near a dz packing area. Not really. There where more than just a handful of 149 lofts. Most of the larger Drop Zones had one nearby that was used by them. If I remember correctly the major manufacturers of the day were also part 149 certified. Para-Flight and National come to mind... As far as basement rigging and 65.127... If you look most do not have a 40 ft table available to them either. Which is still a requirement BTW. 65.127 Facilities and equipment. No certificated parachute rigger may exercise the privileges of his certificate unless he has at least the following facilities and equipment available to him: (a) A smooth top table at least three feet wide by 40 feet long. (b) Suitable housing that is adequately heated, lighted, and ventilated for drying and airing parachutes. (c) Enough packing tools and other equipment to pack and maintain the types of parachutes that he services. (d) Adequate housing facilities to perform his duties and to protect his tools and equipment. Also, spoke to Flight Concepts about receipt/ inspection of materials. Red informed me that his manual (which he is sending me a copy) mandates material control/certification in his QA program. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #16 May 3, 2015 Quote Obviously, the final arbiter would be the FAA. However, IMO it would be technically legal. However, IMO ( again ) I do not think it should be legal. I think that there should be limits on going to this extent. I am in the same boat on this Jerry for the most part. I think there should be limits, but far,far down the chain if you will. Although I do like the ability to use extreme rebuilding:) Aircraft engine mounts and carb heat boxes have always used extreme limits of rebuilding and the FAA knows all about it. This actually helps us out in the aircraft world. A new air box for a C-182 is about $5,000 from Cessna. A total rebuild is $1800.... Quote PS) Edit to add: Many canopy mfrs have limits on how many patches, where, etc. Maybe there should be some limits on rebuilding a harness and/or a container. Hmmmmm! Again, I would be careful of going to deep in the thought process here. Remember you relied very heavily on the "minor" change option for your back to lap conversion. Adding a lot of limits would almost certainly cancel that option later in life if the right people started looking at it. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
JerryBaumchen 1,061 #17 May 3, 2015 Hi Mark, QuoteRemember you relied very heavily on the "minor" change option for your back to lap conversion. You could not be more wrong. There was no 'back to lap' conversion. Jerry Baumchen Quote Share this post Link to post Share on other sites
masterrigger1 2 #18 May 3, 2015 Quote You could not be more wrong. There was no 'back to lap' conversion. Well I guess i am really confused. Before you got that approval, Caleb Glick (washington FAA) phoned me with questions regarding your Lap parachute. He specifically asked me my thoughts on a a "minor " change of that magnitude. that and the purposed "need" of a lap parachute. Is your parachute TSOC23b certified or is it with C23d or later? MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
JerryBaumchen 1,061 #19 May 3, 2015 Hi Mark, Quote Caleb Glick (washington FAA) phoned me with questions Let me say this; I would consider that hearsay. All of my products are certificated under C23(b). That information ( I believe ) is public knowledge, i.e., available under the Freedom of Information Act. All other information regarding any company that I own I consider proprietary information. Jerry Baumchen Quote Share this post Link to post Share on other sites
masterrigger1 2 #20 May 3, 2015 Quote Let me say this; I would consider that hearsay. Jerry, Hearsay is not a testimonial from the person that participated in the conversation. Quote All of my products are certificated under C23(b). That information ( I believe ) is public knowledge, i.e., available under the Freedom of Information Act. Yes, I had not bothered to look it up , that is why I asked. Since knowing that: (1) Your previously held TSO was under C23b (2) Any new products are to be certified under the current TSO (at that time) and TSO23b was a long time ago. (3) Your Lap is rated with TSO23b, so you used the existing TSO. ....Obliviously with changes. (4) "New" products can be made under a change notice of an existing TSO. Like the Vector III over the old Wonderhog... (5) Lastly, the conversation with Glick, who at that time was the head of oversight for Skydiving. Quote All other information regarding any company that I own I consider proprietary information. Rightfully so, but no one is looking into it that deep. MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
jonstark 8 #21 May 3, 2015 Kevin, Not having read all the preceding posts I may be repeating but... Once a certified harness leaves the manufacturer anything done to it is one of two things. It is either being repaired or modified. These may be minor or major. Some have the misconception that if parts and materials from the OEM are used the system may be repaired back to original specs and no change has been made. This is incorrect. Back to my assertion that ANYTHING done after delivery from the OEM is a repair or mod. It is my opinion that it is perfectly legal and proper for an appropriately rated rigger or shop to completely rebuild a harness system as long as the data, materials and work done are as good as the OEM and this is NOT CONTRARY to the OEM's Instructions for Continued Airworthiness. Some might suggest that it can be better but that would be a modification requiring engineering approval either from the OEM or the FAA. Any and all repairs should also be properly documented in the packing data card at least. This should include the nature of the repair/mod, who did it, where, when and their certificate number. Only the OEM may "rebuild" a harness and/or container system. This distinction relates to bringing it back to original, as delivered, zero jump specs. Not to be confused with "overhaul" which brings it back to serviceable specs. Jon Quote Share this post Link to post Share on other sites
