Master riggers & harness work...

[hackish 8]

Technically a master rigger is supposed to be able to do something like a harness resize/repair. I'm more the cautious type who likes to check in with the manufacturer on any major repairs to make sure my proposed work conforms to what they feel is a proper way to fix something.

Manufacturers seem to always say "sorry we don't permit XXX outside the factory". Is it a dirty secret where people get their master tickets and just go fix stuff without ever asking about it? Is it an issue where I just need a bunch of years of training at every single manufacturers facility to be permitted these repairs?

-Michael

[riggerrob 558]

Two distinct answers: legal and practical.

Legally, manufacturers do not want to risk lawsuits instigated by stupid people doing stupid things outside the factory.
Lawsuits do not need to adhere more than loosely to written laws..... they just need some one whining.
For example, Lawsuits continue 8 years after I was injured in a crash. The Superior Court of B.C. quit caring about the wounded (sugery, knee braces, psychiatric counselling, prescription pain-killers, physio-therapy and lost wages) back in 2012. Ever since 2012, lawyers have only bickered about dollars.
The lawsuit has boiled down to the Provincial gov't suing the federal gov't for negligence (poor over-sight, failing to enforce CARs, etc.).

Practically, FARs allow Master Riggers to do most major repairs provided they have the dimensions, materials, tools and skills. As long as a Master Rigger's repair resembles original factory sewing, it passes the first practical test. The ultimate practical test is how many wounded you have to scrape off the ground.

[skytribe 16]

Without getting into a big open discussion about the interpretation of the rules.

Legally a Master rigger can perform major and minor repairs and alterations. This is what the FAA have determined. As Rob has stated it should be done with same dimensions, materials, tools and skills.

The manufacturers may not like it BUT they do not write the regulations.

[linestretch 0]

This is a good topic since we had a harness a master rigger altered and it was ghetto! While I guess it was allowed since he's a master rigger...it came up that he should have filed some paper work with the FSDO...or something along those lines. Can anyone that knows about this comment? With this particular rig, there was no paperwork and the mfg didn't know anything about it either. The rig ended up getting reworked by the mfg and the poor customer basically paid twice.

my pics & stuff!

[skytribe 16]

Does the alteration have to be up to manufacturer standards or simply airworthy ?

A good master rigger would do it so that you would not know the difference. A poor one you may be able to tell that its not factory but completely airworthy.

If you don't have the skills, equipment and materials don't do the work irrespective of if you're a master rigger or not.

AC105
"16. PARACHUTE ALTERATIONS.
a. Configuration. Alterations are changes to a parachute system configuration that the manufacturer or the manufacturer’s supervising FAA Aircraft Certification Office (ACO) has not approved. Examples include removing a deployment device from a reserve canopy, adding
harness fittings to permit attaching an additional canopy, using nonstandard repair materials or techniques, or installation of a specific make/model AAD when the manufacturer has not authorized such changes. Changes that result in an approved configuration are considered repairs
(see paragraph 15).
b. Approval. An alteration to an approved parachute system must be done in accordance with approved manuals and specifications and only by those with specific authorization to perform that alteration.

Specific approval is not needed for the method of altering a non-TSO’d
Par 15 Page 17
AC 105-2E 12/4/13 main parachute canopy.

A person seeking authorization to alter an approved parachute system
should proceed as follows:
(1) A person qualified to alter a parachute (as listed below) should contact his or her local FAA FSDO inspector to discuss the proposed alteration. The applicant should be prepared to show the inspector the nature of the alteration by using a sample assembly, sketch, or drawing and be prepared to discuss the nature of the tests necessary for showing that the altered parachute meets all applicable requirements.
(2) The inspector will review the proposal with the applicant and a plan of action will be agreed upon.
(3) The applicant will then prepare an application, in the format of a letter, addressed to the local FSDO. Attach all pertinent data. The data should include:
• A clear description of the alteration;
• Drawings, sketches, or photographs, if necessary;
• Information such as thread size, stitch, pattern, materials used, and location of altered components; and
• Some means of identifying the altered parachute (model and serial number).
(4) The FSDO aviation safety inspector (ASI) may send an alteration to the ACO for review if the ASI is not experienced in parachute alterations. When satisfied, the inspector will indicate approval by date stamping, signing, and placing the FSDO identification stamp on the
letter of application.
(5) Only a certificated and appropriately rated master parachute rigger, a current
manufacturer of approved parachute systems or components, or any other manufacture"


That should detail what needs to take place to make an alteration and paperwork that needs to be filed.

I'm curious if I ask the manufacturer to make a modification to a container - say something completely one off and non-standard. Do they also need to file ay paperwork as it is different from the standard configuration which the system was designed and tested and approved.

[mark 102]

For US riggers:

All repairs must be done with procedures approved by the FAA or the manufacturer. If a repair is "ghetto," it is not approved. Specific rig-by-rig approval is not required by regulation, though.

There is no FSDO paperwork required for repairs, either major (like harness resizing) or minor (like basic patch).

There is no requirement to note repairs on the packing data card. The only requirement is that it be logged in the rigger's logbook. In one sense, this is okay, since the entire system must be inspected before approving return to service, and it doesn't matter whether a part is original, replacement, or repaired. A notation on the data card is irrelevant to the inspection.

On the other hand, we would like a way to tie a particular repair to a particular rigger or rigging shop. Right now there's no way to do that unless you already know who it is and have access to their logbooks, and assuming the repair has been done within the previous 2 years.

-Mark

[skytribe 16]

Quote

There is no FSDO paperwork required for repairs, either major (like harness resizing) or minor (like basic patch).

So to quote from the FAA parachute riggers handbook - which we know there are differences in opinion on its legal status and what it refers to as a minor, major and alteration.



"Another area of concern is a master rigger who does major
alterations without proper approval of the manufacturer.
The rigger may do major repairs to return the assembly to
its original condition without further authorization of the
Administrator or manufacturer, but alterations are another
story. Title 14 CFR part 65, section 65.129(e), states that “No
certificated parachute rigger may pack, maintain, or alter a
parachute in any manner that deviates from the procedures
approved by the Administrator or the manufacturer of the
parachute.”

There are a number of common alterations
seen in the field. Among them are: harness re-sizing, AAD
installations, RSL retrofits, chest strap relocation, and
others. The manufacturer’s approval can vary from a verbal
message over the phone to a formal engineering procedure
complete with drawings and specifications. If the work is
done correctly, the truth probably lies somewhere in the
middle. If riggers want to ensure they are following code,
they should obtain some form of written approval from the
manufacturer in whatever form they provide. "


This states that a resize is an alteration and not a major repair. To do either you would need to be a Master Rigger but paperwork would need to be filed out for an alteration as you would be returning it in a different condition from the original.

[mark 102]

skytribe

[The Parachute Rigger Handbook] states that a resize is an alteration and not a major repair. To do either you would need to be a Master Rigger but paperwork would need to be filed out for an alteration as you would be returning it in a different condition from the original.

The PRH is partially correct. It would be an alteration if the harness were changed to an unapproved configuration. It is not enough to be an alteration to simply change from the as-manufactured configuration. If a change to the as-manufactured configuration were an alteration, than patching a canopy would be an alteration.

When a harness is approved, it is approved in a range of sizes. Changing the size within the approved range is a repair. (Sometimes it's not even a repair -- it's just moving the webbing through the adjustment friction adapters.) Changing the harness to a size outside the approved range would be an alteration.

Mark

[hackish 8]

“No certificated parachute rigger may pack, maintain, or alter a parachute in any manner that deviates from the procedures approved by the Administrator or the manufacturer of the parachute.”

I took that to mean that the repair had to be approved by the manufacturer. I'm just looking to fix stuff, not do alterations. I see enough garbage repairs that I'm looking to do things right and sometimes it would be nice if the manufacturer would spend 2 minutes explaining how to go about a repair.

Apparently I'm not permitted to make a sigma closing loop, or more technically repair a worn out one by replacing the spectra on it. Why not? They say you can't.

I'm still not confident I know the right answer to this...

-Michael

[mark 102]

hackish

I took that to mean that the repair had to be approved by the manufacturer.

The manner of the repair has to be approved, not a particular repair itself.

Quote

Apparently I'm not permitted to make a sigma closing loop, or more technically repair a worn out one by replacing the spectra on it. Why not? They say you can't.

We've seen enough "nonstandard" stuff to understand why they might say this, but in the US, specific approval is not required for repairs and alterations (appropriate to your certificate) you do to the main.

Mark

[koppel 3]

Quote

"Another area of concern is a master rigger who does major
alterations without proper approval of the manufacturer.
The rigger may do major repairs to return the assembly to
its original condition without further authorization of the
Administrator or manufacturer, but alterations are another
story. Title 14 CFR part 65, section 65.129(e), states that “No
certificated parachute rigger may pack, maintain, or alter a
parachute in any manner that deviates from the procedures
approved by the Administrator or the manufacturer of the
parachute.”

There are a number of common alterations
seen in the field. Among them are: harness re-sizing, AAD
installations, RSL retrofits, chest strap relocation, and
others. The manufacturer’s approval can vary from a verbal
message over the phone to a formal engineering procedure
complete with drawings and specifications. If the work is
done correctly, the truth probably lies somewhere in the
middle. If riggers want to ensure they are following code,
they should obtain some form of written approval from the
manufacturer in whatever form they provide. "


This states that a resize is an alteration and not a major repair. To do either you would need to be a Master Rigger but paperwork would need to be filed out for an alteration as you would be returning it in a different condition from the original.

In the US how would that play out for a Master Rigger who decided to take an older H/C without hip rings and install them as per the method in use by the manufacturer currently?

Paperwork as its an alteration or no paperwork as they currently manufacturer that way?

I like my canopy...


...it lets me down.

[masterrigger1 2]

Quote

In the US how would that play out for a Master Rigger who decided to take an older H/C without hip rings and install them as per the method in use by the manufacturer currently?

Paperwork as its an alteration or no paperwork as they currently manufacturer that way?

Since I have been down that exact road so to speak....

No approval would be required if the manufacturer has two models with and without hip rings using the same TSO.

For example, Relative Workshop/UPT makes the Vector III on the same TSO as the older Vector II and Wonderhog. You can install the Vector III harness on the Vector II legally without approval.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[ChrisHoward 8]

hackish

Apparently I'm not permitted to make a sigma closing loop, or more technically repair a worn out one by replacing the spectra on it. Why not? They say you can't.

Of course they do. But as pointed out earlier in the thread, they do not get to make the rules, the F.A.A. does. That being said, if you "repair" the components you are now responsible which in North America means Liable. I think this scares off more riggers than anything else.

[riggerrob 558]

The Sigma factory does not want outsiders making Sigma closing loops for fear that they will make new loops the wrong length, then the drogue release system will not work correctly.
The last time I made some Sigma loops, they came off the sewing machine the exact (UPT manual) or 1/8 shorter. The customer made such a huge stink - that I will never did business with him again.

By the same token, numerous packers have asked me to make longer bungee stows and longer main closing loops for Strong Dual Hawk Tandems. I tried to explain that those loops are part of a "system" and when you alter any component, you also alter openings. I have jumped Strong Tandems with longer loops and sometimes they opened hard enough to hurt me.
Finally, I mumbled some bureaucratic bullshit about "not being high enough up the totem pole."

[koppel 3]

cheers

I like my canopy...


...it lets me down.

[riggerrob 558]

ChrisHoward

***Apparently I'm not permitted to make a sigma closing loop, or more technically repair a worn out one by replacing the spectra on it. Why not? They say you can't.

Of course they do. But as pointed out earlier in the thread, they do not get to make the rules, the F.A.A. does. That being said, if you "repair" the components you are now responsible which in North America means Liable. I think this scares off more riggers than anything else.

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

Eventually North America will have millions of lawyers, but zero riggers, zero plumbers, zero carpenters, zero mechanics ......
Did I tell you how much I trust the tort law system?
GRRRRRR!

[riggerrob 558]

Sadly, sometimes manuals are written for lawyers first and riggers last.

For example, back when I wrote manuals for Righing Innovations, it seemed that I was writing more to protect RI from liability.

I was trying to write "picture books with simple captions" for riggers who may not have understood English very well.
I disagreed with the editor about one photo that he wanted to delete.l, but the editor out-ranked me and he won. The photo was deleted.

A year later he phoned me to say: "Do you remember that photo?" Seems that a team was complaining about pilot-chute hesitations. They had been packing according to the pictures, but ignored a subtle step only written in the manual. As soon as factory riggers demonstrated the complete packing method, the problem disappeared.

Morale of the story: manufacturers are reluctant to approve any repairs outside the factory because they have seen some "African engineering" that should never be allowed in the air. Not all field riggers have the machines or skills to duplicate factory stitch patterns.

The best repairs so closely resemble factory stitching that skydivers cannot see the difference.

[hackish 8]

riggerrob

Morale of the story: manufacturers are reluctant to approve any repairs outside the factory because they have seen some "African engineering" that should never be allowed in the air. Not all field riggers have the machines or skills to duplicate factory stitch patterns.

The best repairs so closely resemble factory stitching that skydivers cannot see the difference.

Someday I hope to be able to do a repair so well that even the manufacturer will say "We must have done this". The problem I see is that so many manufacturers are so against doing any repair that you get 0 help or instruction from them. Since I've done training at different factories I know that QC documentation exists and is at hand.

Since you can get no help, the cards are already stacked against you on doing a perfect repair. Taking the sigma loop example if they would give details like "tension the loop to x lbs and it must be y inches +/-" then I could guarantee if I made a part it would be in spec and break the self-fulfilling prophecy that nobody in the field can make them correctly.

They make money on parts. At $15 ea plus shipping/exchange/tax and brokerage we're paying about $35 for every loop. While I'm confident in my own team I can see how this can push others to use loops longer. A net result is less safety.

Harness repairs are even more significant. $80-$100 to ship it down. Same to ship it back. 2-3 weeks of waiting. A few hundred dollars in repairs, now the jumper is saying "can't I get a little longer out of this?"

-Michael

[gowlerk 1,914]

Quote

Since you can get no help, the cards are already stacked against you on doing a perfect repair. Taking the sigma loop example if they would give details like "tension the loop to x lbs and it must be y inches +/-" then I could guarantee if I made a part it would be in spec and break the self-fulfilling prophecy that nobody in the field can make them correctly.

If you search you will find a RWS produced instruction sheet for making a closing loop for the military version of the Sigma. The finished length is 7 1/2 inches instead of 8 1/2 though. It's not that hard to adapt it to the correct length.

http://www.cpsworld.com/tech_pdfs/RWS/WI-038_Rev.0-Sigma1290.pdf

Always remember the brave children who died defending your right to bear arms. Freedom is not free.

[riggerrob 558]

Agreed Hackish,
Local riggers can only compete on delivery time.
CSPA has been trying to address the concept of teaching major repairs by adding Rigger A1 and A2 courses.
As for quality control: the best inspection tool is a second set of eyeballs.
Finding a knowledgeable second set of eyeballs is the challenge for field riggers working alone.

For example, last week I relined a Sabre 2. Since I could not get a second rigger to inspect the lines, I asked the customer to inspect the lines when he picked up the canopy. He freely admitted that he did not know what he was looking at, so I gave him a half-hour lecture on inspecting lines. Reading a trim chart was way over his head! But eventually we agreed that all line joints were sewn, lines were symmetrical and trim resembled the factory chart. His last e-mail said: "great opening."

Ideally a second rigger would have inspected those lines before returning the canopy to the customer.

[hackish 8]

I have a cut sheet for the proper length unit. It was merely an example. Designing a replacement that is identical to the original takes a lot more skill than simply following instructions so I think it's no wonder they find so few that are properly made.

-Michael