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jws3

Shortening a Chest Strap

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The FAA handbook is one manufacturer's opinion (the one who wrote it.) NOT the FAA's. Although now inspectors rely on it and some maintain it's the only allowable way to do anything



Correct me if I'm wrong that this is a FAA published document and the FAA regulations are what we are talking about here. If this is the case then, like it or not this is the opinion that the FAA has deemed valid which also may coincide with Sandy's opinion.

I don't see any disclaimer in the front of the document saying - this is the opinion of Sandy Reid and NOT the FAA. I see a FAA document, the author of which is named and is a equipment manufacturer, DPRE and years of experienced. Perhaps if his name wasn't there and it was just an anonymous authored document that would make it more palatable as an official FAA document.

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councilman24

No where NEAR this simple. The FAA handbook is one manufacturer's opinion (the one who wrote it.) NOT the FAA's. Although now inspectors rely on it and some maintain it's the only allowable way to do anything.>:( Poynter's is as much tradition as logical or regulatory interpretation, although again the FAA relied on it in the absence of anything else. Of course very little of Poynter's is original. And there are some inspectors and DPRE's that will tell you the manufacturer's instructions cannot and does not trump an FAA interpretation.

Some of the above I agree with and some don't. And rather than a bar tack many chest straps end with 5 cord harness machine straight stitches.



Unfortunately there is a rift in the opinions of a number of DPREs. For example Mark Lancaster is very passionate about the issue of line changes. I agree with the idea that Sr. Riggers should be limited to repairs appropriate to their training and skills.

The trouble is, AC105-2E is the only guideline that the FAA gives us and they are explicit in their advice. Them's the rules. Perhaps Sandy's opinion is very liberal, but at the end of the day it was the FAA who contracted to have the manual written and they published it. Whether they did their due diligence or not the second it was published, the document became their "opinion".

If the rules were to be changed there are a number of definitions that would need to be explicitly specified and the FAA book revised. The biggest example I can think of is a main canopy. It is not a certified part and therefore has no quality of airworthiness or not and subsequently the definition of major or minor repair cannot be applied. AC105-2F anyone???

In Canada there are a number of levels. Rigger A, Rigger A1, Rigger A2 Rigger B. The Rigger A can only pack sport reserves and do hand sewing. Simple as that. A1 and A2 is a gradual progression to the Rigger B which is equivalent to the Master Rigger. With each level there is training and testing.

I'm not saying it's better, just that it is more clear. The FAA system could use some clarifications but until they come out we only have AC105-2E to give guidance.

-Michael

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Unfortunately there is a rift in the opinions of a number of DPREs. For example Mark Lancaster is very passionate about the issue of line changes. I agree with the idea that Sr. Riggers should be limited to repairs appropriate to their training and skills.



So politics between DPRE's.....

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The trouble is, AC105-2E is the only guideline that the FAA gives us and they are explicit in their advice. Them's the rules. Perhaps Sandy's opinion is very liberal, but at the end of the day it was the FAA who contracted to have the manual written and they published it. Whether they did their due diligence or not the second it was published, the document became their "opinion".



I believe that the moment they published it that it became their opinion is fact. Like it or not, whether right or wrong in your own personal opinion - the fact the FAA published it, in their document means it is their opinion and they make the regulations in the US. So campaign all you want for clarification and change but until then they are what the authority is saying is their opinion and that is what counts right now if you want to remain legal.

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The trouble is, AC105-2E is the only guideline that the FAA gives us and they are explicit in their advice. Them's the rules.



Micheal,
AC-105-2E is NOT regulatory and it is not the only guidance out there.
It offers some very bad guidance (in certain places..) that conflicts regulation.

Also, remember that it was written by the two youngest DPRE's out there.

Lastly, a manufacturer cannot upgrade your privileges but simply stating a repair is a minor one when it is considered by the FAA as a major one.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1


Micheal,
AC-105-2E is NOT regulatory and it is not the only guidance out there.
It offers some very bad guidance (in certain places..) that conflicts regulation.

Also, remember that it was written by the two youngest DPRE's out there.

Lastly, a manufacturer cannot upgrade your privileges but simply stating a repair is a minor one when it is considered by the FAA as a major one.



I agree it is not regulatory but it is the FAA's published opinion on how the regulations ought to be applied. I agree with you 100% that it gives senior riggers too much latitude but just wishing it weren't so doesn't change the FAA's published opinion.

The manufacturer, as stated in the AC105 can dictate whether a repair on THEIR gear is major or minor. They are not in any way changing your privileges. They are merely dictating the privileges required to make the repair. The difference is subtle but important.

Cars on some fictional highway can go 70mph and trucks only 60mph. The manufacturer of the El Camino says look it's a car and here is why. Did they change the speed limit on the road or did they just class their vehicle so it can legally go faster? Same idea.

-Michael

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masterrigger1

Remember that it was written by the two youngest DPRE's out there.



What role, if any, did you or people you know play in this quote from AC-1052D para 15.(c).(2) which did not appear in any PIA or USPA contribution to the AC:
Quote

"The riggers must be aware that any repair on a TSO canopy is a major repair"


I already know the answer. I'm just asking you to share what you know.

Mark

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My opinion:
AC 105 2E is regulatory. In statutory construction and interpretation the more recent and more specific controls.
In many instances, and not just in rigging regulations, these newer or more specific statutes, regs and far's trump the older or less specific ones. They do so because of the legal presumption that legislative body that created the newer or more specific provisions had knowledge of what was previously in existence and have chosen to now modify that. That is the legal guideline for statutory construction and interpretation.

In instances where AC 105 2E does contradict or modify other previously published sources, because it is more recent and more specific, AC105 2E is the current and controlling authority and can be relied upon to legitimize repairs performed as described and who can do them.

Skytribe and Hackish are both correct. And, yes, according to 105 2E an individual manufacturer can reclassify (trump) a repair from major to minor on their own products.

The good news is that rarely do the Poynters and the Parachute Rigger Handbook (PRH) conflict, and I doubt that manufacturers conflict much either. The result is that we have a predictable and unified system for the determination of classification of repairs. This benefits both riggers and those teaching and testing riggers.

For additional confirmation that the FAA has fully endorsed the PRH handbook, one only has to look at some of the tasks for Senior riggers in areas I thru VI of the parachute riggers Practical Test System (PTS). Some tasks which Senior applicants can be tested on, prior to the PRH publication would have been classified as major. Now they are minor and the applicant can be tested on them. The FAA is "all in" on the PRH. It is the "law" now and can be relied upon in case of challenges based upon regulatory infraction or civil lawsuits.

No publication is perfect, and to the extent that the Poynters and the PRH have errors, it is up to us to point them out and get them corrected. I look forward to a newer and better PRH some day, which would be even more specific in task classifications and which would correct previous errors and eliminate ambiguities. If a new PRH is created, there could be a reclassification of who can perform repairs which are considered by the rigging community to be too liberal or too strict, and also consider an expansion of tasks allowed by Senior riggers. I think the FAA would listen to the rigging community as a whole in creating or confirming the present classifications. All would have a voice.

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dpreguy


My opinion:
AC 105 2E is regulatory. In statutory construction and interpretation the more recent and more specific controls.
In many instances, and not just in rigging regulations, these newer or more specific statutes, regs and far's trump the older or less specific ones.



Thank you for your advice Walt. For those who don't know, Walt has an extensive legal background as a trial lawyer and prosecutor. While no one is perfect and no one can read the FAA hearing officer's or judge's mind in the event of an hearing or trial, I do believe Walt's opinion does come from years of legal practice. Therefore I put a lot of credibility in his word.

On a personal note, I am not a 100% fan of the PRH, however I feel the FAA logo on the cover is a very strong defense should I follow the procedures in it, and hopefully to limit all rigger's liability the FAA can refine and improve upon it every 5 or so years making it much better. I wish folks at PIA would help with this (with a positive attitude of making it better, not a negative attitude of the existing version is garbage).

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I agree it is not regulatory but it is the FAA's published opinion on how the regulations ought to be applied. I agree with you 100% that it gives senior riggers too much latitude but just wishing it weren't so doesn't change the FAA's published opinion.



It was a civilian contracted publication that never was reviewed by any of the appropriate people or AFS-100 which is the Legal department of the FAA.

The above mentioned people were made aware of the many conflicting issues inside the AC and it is now being re-written.

So no; it is not their opinion....

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The manufacturer, as stated in the AC105 can dictate whether a repair on THEIR gear is major or minor. They are not in any way changing your privileges. They are merely dictating the privileges required to make the repair. The difference is subtle but important.



What if Cessna said rebuilding a engine was minor repair, do you think the FAA needs to go back and change the PTS for airplane mechanics?

We have standards of testing applicants and they are located
in the PTS (Practical Test Standards). These testing standards are set forth by the FAA and not the manufacturer.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Remember that it was written by the two youngest DPRE's out there.

What role, if any, did you or people you know play in this quote from AC-1052D para 15.(c).(2) which did not appear in any PIA or USPA contribution to the AC:
Quote:
"The riggers must be aware that any repair on a TSO canopy is a major repair"
I already know the answer. I'm just asking you to share what you know.



Purely guessing here, I would say it was three different manufacturers as they all have something that closely states the same in their manuals.

I know it was not me.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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My opinion:
AC 105 2E is regulatory. In statutory construction and interpretation the more recent and more specific controls.
In many instances, and not just in rigging regulations, these newer or more specific statutes, regs and far's trump the older or less specific ones. They do so because of the legal presumption that legislative body that created the newer or more specific provisions had knowledge of what was previously in existence and have chosen to now modify that. That is the legal guideline for statutory construction and interpretation.



Walt,
In the most recent court cases involving AC's, the Federal Judges have thrown the cases out because the AC's are deemed not regulatory.

The last one that I know of was the incident at Virginia Tech involving a drone.

http://www.reuters.com/article/2014/03/07/us-usa-aircraft-unmanned-idUSBREA2618P20140307

It is now a standing policy that AC's are not to be used as law based decisions. Order 8900 is also included in this.

Ask your local FSDO guy about it.


Also something to note is they are now putting a disclaimer on these newer versions of AC's:

1. PURPOSE. This advisory circular (AC) provides information to assist in ........

This AC is not mandatory and does not constitute a regulation. Nothing in this AC changes the legal
requirement for public aircraft operators to comply with the statute.



Quote


For additional confirmation that the FAA has fully endorsed the PRH handbook, one only has to look at some of the tasks for Senior riggers in areas I thru VI of the parachute riggers Practical Test System (PTS). Some tasks which Senior applicants can be tested on, prior to the PRH publication would have been classified as major. Now they are minor and the applicant can be tested on them. The FAA is "all in" on the PRH. It is the "law" now and can be relied upon in case of challenges based upon regulatory infraction or civil lawsuits.




With regards to the PTS and associated tasks, the DPRE should be selecting the appropriate tasks for the applicant in the different areas.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Regulatory may not have been the best adjective.
Binding or authoritative probably would have been better.

The question is, and always has been: "What repairs/tasks can a senior rigger do?"; or stating it another way, "What repairs or tasks is/are a senior rigger prohibited from doing?" One answer is to label or classify that repair or that action as major or minor.

Another way to state what a senior rigger can do is simply to say, "A senior rigger can do this " without the labelling or classification of whether it could or should be classified or defined as major or minor. That is what the Parachute Rigger Handbook and 105 2E do. For example: The PRH simply states what can be done by a senior rigger and what must be done by a master rigger. Perfect! A senior rigger can be confident that he is not exceeding his authority by finding the task or repair and only doing it if it says he can. For those tasks and repairs not listed, then go back to the definition of major or minor. Using the PRH along with AC 1052E as a guide, (which gives respect to the Poynters too), provides the senior rigger, the rigger instructor and the parachute rigger examiner bright lines in determining in determining what can be done by a senior, what to teach and what to test on. The Practical Test System is the testing standard and each examiner is in an appointed position and has the obligation to follow it as part of his duties.

Taken as a whole, this is as nearly a perfect system as could be devised. The senior rigger can confidently perform tasks and repairs as stated in the PRH and 105 2E, -Poynters without fear he is exceeding his authority.

Once again, to the extent that the AC or the PRH or the Poynters are in error; they need only be corrected. To the extent that the AC or PRH is ambiguous, then they should be rewritten to remove the ambiguities. We can all participate in this.

The same old arguments, using the circular debating techniques of going from the specific to the general and back again from the general back to the specific always results in a quagmire of questions and never yields definitive answers; as the conclusions or opinions of what affects strength, operation, weight and balance, flight characteristics, yadda yadda (going on memory here of the def. of a major repair) will always differ. The present system of the AC 105 2E, Poynters and the PRH avoids this opinion-based approach and provides the senior rigger and all others teaching and testing concrete and specific guidance for defining the limits or privileges of a senior rating. No politics, no preference to those with opinions, and specificity are the goals the FAA or of any regulatory system. It seems to me to be working just fine, and we can work together to make these sources better.
The alternative is to have never ending arguments where opinion rules.

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Walt,
It pretty much comes to this:

1. A non-certified owner can only pack a main parachute that he or she will jump. He or she cannot do any maintenance (unless supervised by the appropriate rigger)

2. A Senior Rigger is the next level up, only being allowed to do simple repairs that will not affect airworthiness. This rating is meant to be a beginning rigger. What he or she can do is pack both a main and reserve parachute, replace velcro, make small patches that do not encompass a seam, replace snaps, and assemble/inspect parachutes.

Pretty much the simple stuff....


3. A Master Rigger or the manufacturer does everything else.


Back to the OP's question; Altering the length of a chest strap is plain and simple an alteration which a Senior rigger cannot do with or without any manufacturer's BS.

Cheers,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

Back to the OP's question; Altering the length of a chest strap is plain and simple an alteration which a Senior rigger cannot do with or without any manufacturer's BS.



Except that the OP didn't use the word "alteration." If the manufacturer's TSO drawings/specifications allow a range of lengths, and the result of shortening the chest strap is within that range, it's a repair not an alteration. I tend to think it's probably a major repair, master rigger territory.

On the other hand, there are rigs made without turn-backs on the chest strap, and I don't know of any cases where a chest strap actually stripped out to the turn-back. Some testing I did recently showed the typical load on a chest strap during opening is around 20 or 30 pounds or so, most of which occurs just before the slider comes down. I could be persuaded that there may be designs where shortening the chest strap might be elementary enough to qualify as a minor repair.

Mark

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Guess we'll respectfully disagree on the privileges of a senior rigger. I believe they are very much more extensive.

Hopefully there will someday be input from PIA, or the FAA or simply a consensus of riggers someday to resolve ambiguities.

In the meantime, thank you, and all others for your civility and intelligent input. I learn everyday from those with more extensive abilities and experience than me. Your loft, and others who are in the commercial end of complicated rigging tasks and repairs do things on a
regular basis I wouldn't be able to do. We learn we learn we learn. Pretty cool when you think about it.

As to the OP question, I agree that it is a master rigger task, and if the mfg says no then that's it.

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Except that the OP didn't use the word "alteration." If the manufacturer's TSO drawings/specifications allow a range of lengths, and the result of shortening the chest strap is within that range, it's a repair not an alteration. I tend to think it's probably a major repair, master rigger territory.



The FAA defines any change from the original manufactured configuration an alteration, so that is where I was coming up with the term alteration.

You are right.
The manufacturers have different chest strap lengths that are approved, but once out in the field, changing from one to another would be in that term an alteration according to the definition.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

The FAA defines any change from the original manufactured configuration an alteration, so that is where I was coming up with the term alteration.



I'm not sure that's correct. For example, patches on a canopy are usually repairs, not alterations, even though the manufactured configuration is patchless. Please provide the reference for your definition.

Mark

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Please provide the reference for your definition.



Mark,
That came from 8300 Volume 2, Chapter 28 IIRC, which was the inspector's handbook. It also is a test question in the FAA Parachute rigger's written test and has about 4 different variants of that question.

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I'm not sure that's correct. For example, patches on a canopy are usually repairs, not alterations, even though the manufactured configuration is patchless.




You've got to be kidding..................[:/]

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

It also is a test question in the FAA Parachute rigger's written test and has about 4 different variants of that question.



There are several questions that ask you to distinguish a repair from an alteration, but I don't remember any that differentiate between returning equipment to its originally manufactured configuration vs. the current approved configuration. Let's say my Vector came with the old-style RSL lanyard and I wanted to replace it with the new split style. You're saying that I'm not allowed to do that because it wasn't the original configuration?

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masterrigger1

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Please provide the reference for your definition.

That came from 8300 Volume 2, Chapter 28 IIRC, which was the inspector's handbook. It also is a test question in the FAA Parachute rigger's written test and has about 4 different variants of that question.



8300.10 Volume 2, Chapter 28: "Certificate Parachute Rigger/Added Rating" has been withdrawn, and the contents incorporated into 8900.1. It didn't contain the definition you claim anyway. 8900.1 also contains no definition of alteration like the one you claim. But I'm sure it's there somewhere. If you keep looking, you will find it! When you do, please quote it.

The written test has a number of Part 65 questions on alterations (who may do alterations, which ones are required to be logged), and 4 questions which give examples of alterations (dyeing a canopy, installing an AAD, and 2 questions on plating hardware). There are no questions that ask about the definition of "alteration" or that suggest that changes to the as-manufactured configuration are alterations.


Mark
a not-so-young rigger
over 35 years of experience with parachutes and parachute regulations

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Let's say my Vector came with the old-style RSL lanyard and I wanted to replace it with the new split style. You're saying that I'm not allowed to do that because it wasn't the original configuration?



Yep!
There was a big long discussion about it a few years ago on here. Search for it.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Quote:
Please provide the reference for your definition.
That came from 8300 Volume 2, Chapter 28 IIRC, which was the inspector's handbook. It also is a test question in the FAA Parachute rigger's written test and has about 4 different variants of that question.

8300.10 Volume 2, Chapter 28: "Certificate Parachute Rigger/Added Rating" has been withdrawn, and the contents incorporated into 8900.1. It didn't contain the definition you claim anyway. 8900.1 also contains no definition of alteration like the one you claim. But I'm sure it's there somewhere. If you keep looking, you will find it! When you do, please quote it.




Here you go:

8300.10, Paragraph 13, b...
B. Any change to the configuration, method of
operation, or method of packing the main parachute, up to
and including the main canopy attachment links or the male
end of the quick release fittings, is a main pack alteration.
Any main parachute alteration that affects the strength or
operation of the auxiliary parachute, including the harness,
must be regarded as an alteration of the auxiliary parachute
and handled accordingly.


MEL

DPRE since 1995
First Jump September 30th, 1976
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

Here you go:

8300.10, Paragraph 13, b...
B. Any change to the configuration, method of operation, or method of packing the main parachute, up to and including the main canopy attachment links or the male end of the quick release fittings, is a main pack alteration. Any main parachute alteration that affects the strength or operation of the auxiliary parachute, including the harness, must be regarded as an alteration of the auxiliary parachute and handled accordingly.



That's it?

Why would you choose to interpret "configuration" to mean "manufactured configuration" instead of "approved configuration"?

BTW, the correct reference for your quote is 8900.1, Volume 8, Chapter 5, Section 8, paragraph 8-476, subparagraph B.

Mark

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That's it?



Yep, close enough.

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Why would you choose to interpret "configuration" to mean "manufactured configuration" instead of "approved configuration"?



Because mains do not have to be approved.

Quote


BTW, the correct reference for your quote is 8900.1, Volume 8, Chapter 5, Section 8, paragraph 8-476, subparagraph B.




The reference that I used is an old one before it was moved to 8900.1.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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masterrigger1

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Why would you choose to interpret "configuration" to mean "manufactured configuration" instead of "approved configuration"?


Because mains do not have to be approved.



Why would you choose to interpret "configuration" to mean "manufactured configuration" instead of "designed configuration?"

And specifically with respect to chest straps, which manufacturers specify exact lengths as opposed to a range of lengths?

Mark

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