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Firebolt580

Custom art on rig

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So what is an "Alteration"?



It is a change of the original manufactured configuration.
In other words, if it was manufactured with a ROL and you change it to a BOC, that work is an alteration of the original manufactured version.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Cop out. You can do better then that.

So what if the manufacturer also builds the rig with BOC's? The manufacturer builds that version. Is it still an Alteration to change This rig to That version? If you say yes based on the original version of this particular rig then how about some of the other examples I gave concerning the materials tracking issues with repairs now no longer matching the original construction data? Changes in harness measurement? Changes in components like ripcords, cutaway handles, main PC, main bag, main slider systems?

Lee
Lee
[email protected]
www.velocitysportswear.com

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Hi Mark,

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But I know that you are never in favor for any government oversight with regards to rigging and always seem to lean in that direction.



To the best of my knowledge, I have never advocated for this. I do advocate for getting rig of the TSO certification for gear.

If I am wrong, I will happily be corrected.

Quote

A FAA inspector or any manufacturer cannot change the regulations



I agree. However, they can waive the regs. I had a FSDO employee do it for me, once.

Again, we will have to agree to disagree.

Only the FAA has the last word on what their rigs mean. Everything else is opinion; and that includes me.

Jerry Baumchen

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RiggerLee

So what is an "Alteration"?



It is a change to the approved configuration.

For example, most harnesses are approved in a range of sizes. Changing the as-manufactured length of the main lift web is a repair, as long as the result is within the approved range.

On the other hand, most harnesses are approved with specific webbing types for each of the harness components. Changing from one webbing type to another is usually an alteration, even if the new webbing is stronger. For example, changing the main lift web on a Mirage chest & hip ring harness from Type-8 webbing (rated for 4000 pounds) to Type-7 (rated for 6000 pounds) would be an alteration. Similarly, hanging the MLW on an RI chest & hip ring from Type-7 to Type-8 would be an alteration.

-Mark

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Ok, so if a harness is approved in multiple configurations, or in this case lets say over a range of lengths. And you are calling this change from the original construction length, with in that range, a repair because they manufacture other containers of that pattern set to those lengths. In other words there is a president for it to be built in that approved configuration even though this particular rig was not. And based on that you call this a repair. So how about the ROL to BOC question? If they built this rig in both configuration, and you were to change it from one to the other, would that be an alteration or a repair?

Lee
Lee
[email protected]
www.velocitysportswear.com

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RiggerLee

So how about the ROL to BOC question? If they built this rig in both configuration, and you were to change it from one to the other, would that be an alteration or a repair?



The following paragraph was in the very first draft of AC 105-2D I presented in the PIA Technical Committee, and remained unchanged through all subsequent drafts because there were no objections.

AC 105-2E para 15.a.(3): "If an operation results in an approved configuration, the operation is considered a repair. For example, if a parachute system is approved with and without an RSL, then removing or replacing RSL components is a repair that may be major or minor depending on whether, if improperly done, it might appreciably affect airworthiness. Similarly, resizing a harness, when the original design permits a range of sizes, is a repair when the resized harness remains within the permitted range."

For your ROL/BOC question, if both configurations are approved, changing from one to the other is a repair, not an alteration.

BTW, you should just bite the bullet and get your master ticket. If our schedules overlap in Eloy AZ or Baldwin WI, I'd be happy to do your exam. Then even if someone were to claim ROL-BOC is an alteration, you could do it without asking because they are main components and a master rigger doesn't need to ask before altering a main component.

-Mark

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Firebolt580

Was thinking about getting some custom artwork done on my dolphin container by a friend using a air brush. Is there a specific kind of air brush paint that should be used on it so the rig won't get ruined or any treatments ?



Damn, that is one heck of a rigger pissing contest. Anyway, the short answer is don't, not because of anything they said. I'm going to make an assumption, 1- you're jumping a dolphin (no offense but lol) so you'll be selling that soon. 2 - because you are interested in this at all, you are a low time jumper, so you will be selling that rig soon. Keep the resale value decent, no one wants someone else's crappy art on the rig they are buying.

Also, I know a couple people who have custom rigs, and unless they are sponsored, everyone makes fun of them for it (whether they know it or not).

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Unless the art work is awesome, like some of the old racer pop tops.


So to the question of SB and who the manufacturer can authorize to perform them. If the manufacturer is making a change to the system. Establishing a new approved design, possible discarding the old one, then is performing the SB, bringing the rig into compliance with this current approved configuration, an alteration to the design and who can they authorize to perform it? Examples: SB on the old Reflex containers where they pulled the grommet and slipped in a peace of tape and reset it upside down. Could they authorize a senior rigger to perform this SB? Let's take a bigger example. The Mirage cypres cutter mod. Moving the Cutter from one flap to another and sewing that channel on. Bigger job but I should point out that the very argument for being able to include the AAD in the design at all is that it in no way affects the normal function and airworthiness of the rig. That was the argument for it not affecting the TSO. So whether it works or not, whether the wires are under stress and break or not. None of it theory affects the normal function or the TSO. So if it's irrelevant to airworthiness, the argument for it's inclusion in the first place, could they authorize a senior rigger to perform that SB. If this is not an "Alteration" and the function of the AAD can not affect airworthiness is this a minor repair or a major one.

Some of this is stretching the point a bit but bringing it back around to the original question. What are the boundaries of what a manufacturer can authorize a senior rigger to do in a SB. By the definition of any action that brings a rig in to compliance with an approved configuration being a repair not an alteration, and if the manufacturer has a lot of leeway in determining what they call a minor or major repair, then they could in theory authorize many SB to be performed by senior riggers.

I don't really see any of this as a problem. Generally I think SB are well written and do not stretch the pribbledges or capabilities of the rigger that are authorized to perform them. But the Masterrigger1 guy brought up the question and all else follows from it.

Lee
Lee
[email protected]
www.velocitysportswear.com

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***Unless the art work is awesome, like some of the old racer pop tops.
..........

Lee[/quote

----------------------------------------------------------------------

If you paint or embroider on a non-structural part - while the rig is unpacked - I don't care. By non-structural, I mean: pin cover, pilot-chute cap, leg pad and maybe even a riser cover. It helps that most pin covers are multi-layer (MDS plastic, ballistic nylon, para-pack, Cordura, foam padding, etc.) so that even if you ruin the outer layer, it will not affect function.

OTOH if you spray adhesive paint (epoxy or cyanoacrylate) on a single-layer reserve side flap - while packed - I will not let you jump it. I fear that adhesive paint might penetrate the side-flap and free-bag and glue the reserve closed.

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Hi Rob,

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it will not affect function



IMO this is the unknown.

Many people might agree with you. It would interesting to see what the mfr of any given rig might say.

I build PEP rigs and if anyone paints anything on one of them anywhere, I will never approve it.

If I did and I did not do some additional testing ( just how much paint & how much testing would be up for discussion; and, in the end, probably indefensible ) to determine the effect, I would not have a leg to stand on in court.

Jerry Baumchen

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OP: Take the advice regarding safety, legality and resale value to heart.

Mr. Rickerby was a local legend when I started jumping up here in '93. I'm sorry I never had the privilege of meeting him in person, but I got to admire several rigs, primarily Racers, enhanced by his creativity. Words can't describe his extraordinary vision and execution.

http://www.davidrickerbyart.com/c/ra.html

http://www.dropzone.com/forum/Community_C7/Blue_Skies_-_In_Memory_Of_F48/David_Rickerby_P3388802

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mark

***So what is an "Alteration"?



It is a change to the approved configuration.

For example, most harnesses are approved in a range of sizes. Changing the as-manufactured length of the main lift web is a repair, as long as the result is within the approved range.


That's an interesting definition that I'm not sure I agree with (I'd be curious to see how you arrived at that conclusion and from which documents) (nevermind, that will teach me not to read to the end of the thread), but even if, that is a major repair and thus outside of the SR rating. The FAA circular and the resulting prevailing understanding is that a major repair is anything that "if improperly done, might appreciably affect ... structural strength, performance, or other qualities affecting airworthiness". Resizing MLW definitely falls into this category, AND is touching a TSO'd component of the rig on top of that.
"Skydivers are highly emotional people. They get all excited about their magical black box full of mysterious life saving forces."

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riggerrob

It helps that most pin covers are multi-layer (MDS plastic, ballistic nylon, para-pack, Cordura, foam padding, etc.) so that even if you ruin the outer layer, it will not affect function.



And what if your now ruined fabric allows the stiffener to cut through it (that it otherwise wouldn't), till it causes lines to snag and horseshoe the main to your back? That is rarely fun.
"Skydivers are highly emotional people. They get all excited about their magical black box full of mysterious life saving forces."

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Yup. At 2:56 there are photos showing the cause. According to the description, this is a botched SPSB03032000 main closing loop retainer mod.
"Skydivers are highly emotional people. They get all excited about their magical black box full of mysterious life saving forces."

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It quite clearly came apart. I don't recall seeing sunpath say "and be sure to leave a bunch of fabric flapping around for lines to cinch on" anywhere in the SB.
"Skydivers are highly emotional people. They get all excited about their magical black box full of mysterious life saving forces."

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  1. Not according to any of the riggers I've learnt from. While the rules don't specifically address TSO, the rule of the thumb has always been "if it's a TSO component, treat it as major by definition, unless specifically cleared by mfr/FAA".
  2. Cutting and restitching the MLW is still not minor. Unless you're saying that done improperly it is not likely to affect the airworthiness?

"Skydivers are highly emotional people. They get all excited about their magical black box full of mysterious life saving forces."

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mathrick

  1. Not according to any of the riggers I've learnt from. While the rules don't specifically address TSO, the rule of the thumb has always been "if it's a TSO component, treat it as major by definition, unless specifically cleared by mfr/FAA".
  2. Cutting and restitching the MLW is still not minor. Unless you're saying that done improperly it is not likely to affect the airworthiness?



With respect to (1): that rule of thumb is not a rule. US riggers may do minor repairs on any parachutes for which they are rated. Part 65.125(a)(1). Examples of minor repairs: basic patch on a reserve canopy, not involving seams, crossports, tapes, or bartacks; restitching seams and binding tape; replacing harness velcro for cutaway pillows and ripcords where structural stitching is not affected; hand tacking.

With respect to (2): I agree that resizing a harness within the approved range is major repair.

-Mark

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How about retacking the ripcord housing? Repairing, shortening, replacing or just retacking broken zigzag stitches of leg pads? How about replacing dinged, burred grommets? Replacing broken had tacking on reserve PC's. Replacing loops in pop top PC's Like strong PEP. Tacking risers, ripcord pockets. Most manufactures allow sen riggers to do repairs on their canopies. They generally give some kind of guide line as to what constitutes minor and major, Size, distance from seam, location on canopy, etc.

Point is we work on TSO'd components all the time.

Lee
Lee
[email protected]
www.velocitysportswear.com

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As the the Javelin thing. Even when done properly It still leaves a stiffened lip for a line to sench bellow. When yo pull on it the tong would squeeze in below that lip giving it a good place to catch on and lock down around. Pull and you start breaking those stitches and stripping the tape upwards. I think you're looking at the after math of a horseshoe tearing that stitching. I never thought much of that retrofit mod. I don't think they had a lot of faith in it ether. They went 10,000 rigs and 10,000,000 jumps before it happened the first time. I think it was propaganda so they could say that they fixed some thing. They figured they could go another 10,000 rigs and another 10,000,000 jumps before it happened again to one of their "Modded" rigs. And I'd say those guesses turned out to be just about right. Actuaries rock!

Lee
Lee
[email protected]
www.velocitysportswear.com

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So just a quick question for you riggers, I was wondering about the FAA stuff and it's application related to my experience with some law enforcement folks I'm friends with.

I don't know anything about FAA regs, and quite frankly I don't care about them in relation to skydiving. But you all seem to love picking them apart. So I pose the question, do you think they are intentionally vague so that the FAA can use it's own judgement for when/how to enforce them?

I ask because after talking to LEO friends about a variety of cases and complaining that "the law is so vague" they always respond "It is suppose to be, because that gives us(LEOs) and prosecutors the ability to use personal discretion and judgement." The same reason almost no judge supports "mandatory" sentences. They have also stated that traffic law is written in such a way that they can pull someone over basically at will "I've never had to follow anyone for more than a minute or two before they gave me a reason to pull them over for suspected DUI." The reasoning is that it gives them the ability to make a stop even if there isn't a glaring violation.

So anyway, do you think the FAA is up to the same thing, and trying to pick apart and carefully define the rules might be without cause, at least from a legal standpoint not a "this isn't safe" standpoint?

(e.g. if people are airbrushing pop tops and they(FAA) don't care, they aren't obligated to intervene, but if people start making (and jumping) rigs like UPT's artistic snake skin/leather/steam punk stuff, or take a bedazzling gun to them, they have the ability to shut it down?)

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Cop out. You can do better then that.



Not a cop out. Just was in a hurry to get out the door for vacation..

Quote


So what if the manufacturer also builds the rig with BOC's? The manufacturer builds that version. Is it still an Alteration to change This rig to That version? If you say yes based on the original version of this particular rig then how about some of the other examples I gave concerning the materials tracking issues with repairs now no longer matching the original construction data? Changes in harness measurement? Changes in components like ripcords, cutaway handles, main PC, main bag, main slider systems?



This was covered in the deal when Cypres conversions first came out and also during the Javelin RSL issue.

It also is covered in a document covering the definition of alterations across the board for the FAA.

From FAA letter dated September 24,2001:

The definition of "alteration" in the draft advisory circular entitled "Repair and
Alteration Data" reflect changes other than those to an "original" product.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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