Who can reline a canopy?

[netslide 0]

I ask this since I'm working on getting my riggers ticket. The master rigger I'm working under has made it clear to me the changing a line set is a master riggers job as I understand it.

However this weekend I was visiting a drop zone I frequently jump at and decided to spend time in the loft. While I was the there two senior riggers were both doing relines and they said that because mains are not tso'd that it's a normal practice. There is no master rigger at this dz.

My understanding is that any major modification or repair to a canopy that could affect airworthiness would be considered a major repair requiring a master rigger.

Which is correct?

[RiggerLee 61]

In a technical since I'd say that it's a master rigger job. Major repair. However the reality is that things like this are dome by senior riggers all the time. I should point out that a master rigger can supervise the work. That brings up the question of what constitutes "supervision". Some people would say available for consolation. So in theory if there was a master rigger on site at the dropzone that would count. It's a bit of a stretch but that's the kind of argument that they've used for packers working on the floor. Maybe one of them is a rigger and is there for available. If he comes over and inspects it when they are done, I think that should count. Generally this consist of him yelling from across the room, "Are you done yet?" If he's satisfied with that as an inspection I say it's on him. Some would say that he's supposed to be standing over your shoulder at all times. That's BS. Never happens. Even in training scenarios they check in only periodically at stages in the work.

Around here you can't throw a rock with out hitting a rigger. One at least is generally a master. That's why I never bothered getting mine. In this case since there is no paper work who's to say how closely he was supervising people. Maybe that should change. It's different in Europe and other places. But the reality is that work on mains is often done by senior riggers or even just by the owner. Since there is no paper trail... no proof no foul. Don't give that answer in your test. Just take it to heart.

Lee

Lee
[email protected]
www.velocitysportswear.com

[riggerrob 558]

Written rules (de jure) say that lines can only be replaced by Master Riggers, because if installed improperly, new lines may adversely affect strength, opening or flying characteristics.

In practice (de facto) many senior riggers "exceed their certificates" by re-lining parachutes. Since the courts have not decided precedent, any injury resulting (from poorly installed lines) will see the senior rigger standing alone on court.

As for Master Riggers supervising more junior riggers - doing major repairs (e.g. line replacement) - the Master Rigger must do the final line continuity check and trim check and ensure that all the lines are correctly sewn before signing on top of the less-experienced rigger's' work.

[RiggerLee 61]

If you want a more convoluted argument... A major repair is one that can affect the AIRWORTHINESS of the equipment. That brings up a question of the definition of airworthiness. Not standard for mains. No testing to that standard. No certification. No approval. That being the case how can you define it or any thing you do alter it. So maybe you throw out the statement of it being safe. Again no definition. Well you just grounded every fucking main straight from the factory. Want me to start listing the mains that I've watched collapse? I not sure I have the time to list all of them. Want to talk about safe decent speeds or total speeds. Student canopies would pass, yours probable wont.

Or you could say that you are the manufacturer. You are re manufacturing a canopy from sub components. If you signed or stamped it I think you could say you built it. I can provide presidents for this. It's actually very common.

There have been other arguments made in the past talking circles around the issue. In the end it just comes down to the reality of what is necessary in the sport. This is what day to day reality dictates. I think the FAA should just give up on non approved gear but until then we play word games.

Lee

Lee
[email protected]
www.velocitysportswear.com

[RiggerLee 61]

So that your standard of inspection. I think that's a good standard. Show me where it's written down in the FAR's. Be nice if it was. I wouldn't mind another set of eyes looking over my work to find my mistakes. But generally they just yell at me asking why I'm not done yet.

Lee

Lee
[email protected]
www.velocitysportswear.com

[mark 102]

From the 1971 Poynter's Manual, line replacement on a [round] main may be done by a senior rigger, line replacement on a [round] reserve may be done only by a master rigger. The standards have always been different for mains and reserves.

The day you earn your master rigger certificate, you will be allowed to replace reserve lines. Wouldn't it be nice if you could practice on main canopies first, where you could see your results without having to worry about catastrophic results?

As RiggerLee mentioned, main canopies do not possess this quality called "airworthiness." Airworthiness is defined only for reserves via TSO standards. If the main does not have airworthiness, how could your repair affect it?

I have roughly 20 different drafts of AC105-2D/E from the original proposal to the current published version. In every one, main canopy line replacement is specifically called out as a senior rigger task, which means that roughly 20 times at least several members other than me on the PIA Technical Committee had an opportunity to comment or make a change and they did not. And on at least two occasions, the entire committee reviewed and approved the PIA portion. I do not know the motives of all those who say that main canopy line replacement is limited to senior riggers, but at least one of the most vocal is quite frank in admitting that it's about the money. It's also easier to teach a senior rigger course if you eliminate all line work.

-Mark

[netslide 0]

So in other words as long as its on a main canopy anyone can attach new lines?

One of the questions in the rigger test bank asks, is a line replacement a major repair? What would be the official answer to that?

[JerryBaumchen 1,047]

Hi Mark,

Quote

main canopies do not possess this quality called "airworthiness."

And this is the very reason why I advocate that PIA should petition the FAA to change their documentation such that anyone can do work on any part that has never been subject to any standard of any type.

End of rant; have a nice day.

Jerry Baumchen

[betzilla 56]

Quote

The day you earn your master rigger certificate, you will be allowed to replace reserve lines. Wouldn't it be nice if you could practice on main canopies first, where you could see your results without having to worry about catastrophic results?

I totally agree with this. I did literally hundreds of main relines as a senior rigger, at first with minimal 'supervision,' then totally on my own. During this same period I diagnosed and reworked several grievous errors made by Master Riggers who had relined canopies. I also replaced some reserve lines for a Master Rigger who did not feel comfortable doing it himself, but who knew I had the skill to do it (he did supervise those jobs, since he would be logging the work).

Until it becomes true that Master Riggers are actually better at the work, it just doesn't make sense to say only they can do relines, especially when we are talking about just installing linesets built by the factory.

I *could* see an argument that only a Master Rigger may manufacture a replacement lineset, but even there I have little faith that the average master rigger is particularly good at that (I'm a strong believer in factory made parts wherever available).

[jumpsracer 5]

Anyone can re-line a main canopy...non-tso'd. Many years ago a company made a do-it-yourself canopy you could make at home.

[RiggerLee 61]

That is the question. If you call it a repair then only a rigger can do it. If you call it a major repair then only a master rigger can sign it off but there is no paper work so there is no where for him to sign.

And then what about the people that are, not years ago, but today, building their own main canopies. The manufacturer can do any thing. You don't have to be a rigger to be a manufacturer. If you are building it your self then you are god. What if you say that you are building a new canopy from sub components. There are presidents for that. Aerodyne and others payed PISA to sew their canopies and then just did the line sets here for a long time. But Aerodyne was the manufacturer not PISA. Vertigo payed PD to make their canopies but then finished the assimbaly by sewing on the tail pocket and side panels with the logo. Vertigo was the official manufacturer not PD.

It's all bullshit so that we can do what needs to be done any way. The world would come to a crashing halt if every one who was not a master rigger suddenly refused to do relines. I think back to how many I and others did over the years. The master riggers in the area could not have kept up with the work. And forget the manufacturers. They would have been swamped. Why do you think PD sells line sets to any one with $200. Hell the last time I needed a line set, admittedly it was for a big cargo canopy, the manufacturer could not do it. They were swamped. It was going to be months. I wound up buying 1,300 yards of line, it's a big line set, from CSR and building the thing. You do what you have to do.

Lee

Lee
[email protected]
www.velocitysportswear.com

[mark 102]

netslide

So in other words as long as its on a main canopy anyone can attach new lines?

One of the questions in the rigger test bank asks, is a line replacement a major repair? What would be the official answer to that?

The question(s) in the rigger test bank specify whether it's a main or reserve/auxiliary/emergency canopy. Our students report the answer is scored correct for main canopy relined by senior rigger. That is, the expected answer(s) conform to AC105-2E para 15.c.(2).

-Mark

[Hooknswoop 19]

FAR Part 105.3;

"Direct Supervision means that a certificated rigger personally observes a non-certificated person packing a main parachute to the extent necessary to ensure that it is being done properly, and takes responsibility for that packing."

Derek V

[RiggerLee 61]

"Direct Supervision" and it's still rather flexible. It's more a statement of responsibility stating that the task of supervision can not be delegated but leaving the degree of supervision open to interpretation.

Lee

Lee
[email protected]
www.velocitysportswear.com

[masterrigger1 2]

Quote

I ask this since I'm working on getting my riggers ticket. The master rigger I'm working under has made it clear to me the changing a line set is a master riggers job as I understand it.

1.It is a master rigger's job. It is a major repair. No matter what the liberals on here say that is what it is.

2.There is absolutely no difference between a major repair on a main versus a reserve. That claim is total hogwash! It was discussed and documented during the re-write of 65.111

3.AC-1052E is loaded with errors or liberal views/statements. This BS about repairs being different is total nonsense.

4. The regulations stand over any statement in a AC BTW. With that said, major repairs or for master riggers or someone under their supervision.

5. One certain rigger on here should understand this totally. He put on a line set backwards/incorrectly and the guy died.

So with that said, is it a major or minor repair!?

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[gb1 2]

I have held an IA (aircraft inspection authorization) for 25 years. I have noticed a strong parallel between aircraft repair procedure and parachutes. With aircraft there is a term called preventative maintenance and scheduled maintenance. Any A&P mechanic can overhaul an engine because it falls under these categories and is in the maintenance manual required at a specific time. Obviously could affect the airworthiness of the bird. In most parachute manuals, line replacement is required when out of trim or when worn because of those damn sliders. On that note, perhaps the answer here would be that the PIA or FAA or manufacturers should adopt a " preventative maintenance or scheduled maintenance" attitude for parachutes. I do suggest factory line sets and approved parts for this kind of maintenance. Just a thought. Let's hear it Terry.

[masterrigger1 2]

Quote

Anyone can re-line a main canopy...non-tso'd. Many years ago a company made a do-it-yourself canopy you could make at home.

.and they all violated the regulations.
Non-TSO'd equipment still requires the same standard of repair, repairman and certificates.

From the 65.111 clarification:

"...This rule clarifies that the FAA
requires that a person must hold an
appropriate current parachute rigger
certificate or be under the supervision of
an appropriate current certificated rigger
to maintain or alteration of parachutes...."


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

Quote

As RiggerLee mentioned, main canopies do not possess this quality called "airworthiness." Airworthiness is defined only for reserves via TSO standards. If the main does not have airworthiness, how could your repair affect it?

Totally not true.
They both are subject to airworthiness conditions.Anything that flies and the FAA has to deal with has airworthiness standards.


From FAA 8900.1

8-476 ALTERATION OF THE MAIN PARACHUTE.
A. Requirements for Main Parachute. The main parachute of a dual-parachute pack to
be used for intentional jumping may be altered by a master parachute rigger, the manufacturer, or
any other manufacturer the Administrator considers to be competent. The alterations are not
required to be made in accordance with approved manuals and specifications (§ 65.125(c)).
Master parachute riggers are not required to comply with §§ 65.127 through 65.133 (relating to
7/24/14 8900.1 CHG 0
3
UNCONTROLLED COPY WHEN DOWNLOADED
Check with FSIMS to verify current version before using
facilities, equipment, performance standards, records, recent experience, and seal) when altering
the main parachute.
B. Main Pack and Reserve Parachute Alterations. Any changes to the configuration,
method of operation, method of packing the main parachute, including the main canopy
attachment links or the male ends of the quick-release fittings, is a main pack alteration. Any
main parachute alteration that affects the strength or operation of the reserve parachute, including
the harness, must be regarded as an alteration of the reserve parachute and handled accordingly.


Also from the old AC-105-2C which was a good reference for years:

AC-105-2C, paragraph 12;

12. REPAIRS. Parachute repairs can be classed as major repairs or minor repairs. A major repair, as defined in FAR Section 1.1, is a repair **...that, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness.” (Balance and powerplant operation do not apply to parachutes.) A minor repair, as defined in FAR Section 1.1, ...means a repair other than a major repair." Major repairs to parachutes may be made by a master parachute rigger, an appropriately rated parachute loft, or a manufacturer. Examples of major repairs are replacement of a canopy panel or suspension line, or sewing a large patch on a canopy. The parachute manufacturer’s instructions should be followed when completing repairs to any portion of the parachute.

I have copies of the regulations back into the 1930's that show the same principals and statements that the above states.

Unless the regulations change, line repairs to a main parachute will always be a major repair.

Quote

I have roughly 20 different drafts of AC105-2D/E from the original proposal to the current published version. In every one, main canopy line replacement is specifically called out as a senior rigger task, which means that roughly 20 times at least several members other than me on the PIA Technical Committee had an opportunity to comment or make a change and they did not.

Again not true!
While I was not on the Technical commitee, I did submit a revision as did others. It fell on deaf ears.....

Quote

I do not know the motives of all those who say that main canopy line replacement is limited to senior riggers, but at least one of the most vocal is quite frank in admitting that it's about the money.

The motive is to follow and teach the regulations.This is something that you stray off course on a lot.

I would say that I am probably the most vocal, and it's not about the money on my end.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

Quote

I totally agree with this. I did literally hundreds of main relines as a senior rigger, at first with minimal 'supervision,' then totally on my own.

I don't think I would publicly admit that.

Quote

I also replaced some reserve lines for a Master Rigger who did not feel comfortable doing it himself, but who knew I had the skill to do it (he did supervise those jobs, since he would be logging the work)

Was this the same master rigger that supervised the main line work?

A line on a reserve is made, installed, and final inspected just like a main. there is absolutely zero difference between the two.

Quote

Until it becomes true that Master Riggers are actually better at the work, it just doesn't make sense to say only they can do relines, especially when we are talking about just installing linesets built by the factory.

So in your past experiences, how many mistakes were made by senior riggers vs master riggers in work that you found?

I find mistakes/errors by senior riggers all of the time on canopies that come in my shop. I have quite the photo collection to prove it.

It is very rare to find the opposite in my past experiences.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[gowlerk 1,903]

Meh....Come to Canada. Reline all the main canopies you like. Ship them to the US afterward if you want. Without enforcement there is no point arguing about regulations. And there is zero enforcement in this area in the US either. So we regulate ourselves. Be careful and be sure you know what you are doing.

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

[mxk 1]

masterrigger1

I find mistakes/errors by senior riggers all of the time on canopies that come in my shop. I have quite the photo collection to prove it.

It is very rare to find the opposite in my past experiences.

I'm not disagreeing with you on your main point, but there are a few issues with using your personal experience of finding errors made by senior riggers as evidence that master riggers are more careful in their work.

First, I'm guessing that you see a lot more work done by senior riggers than master riggers. From this fact alone, you should expect to see more mistakes made by senior riggers even if there was no statistical difference in mistakes between the two groups.

Second, not all senior riggers aim to become master riggers. I know a few who have been senior riggers for decades. Since everyone starts out as a senior rigger, you would expect to see more mistakes from them due to inexperience. Being a senior rigger, however, should not be equated with inexperience.

Third, the quality of the work is probably most influenced by your recency of experience, the frequency with which you perform that task, and the total number of times that the task was performed. There is already a bias against senior riggers in all of these areas with respect to more complicated tasks, like relines, in part due to a disagreement about privileges (as this thread demonstrates). When these things are lacking, the time pressure under which the task was executed becomes an important factor in predicting mistakes. I, for example, don't do a lot of rigging, so I take plenty of extra time to double- and triple-check my work. Senior riggers working in a loft under time pressure, and with the other factors stacked against them, may make more mistakes on average, but these aren't factors that are tied to their certificate or training.

Fourth, this: http://parachutistonline.com/content/master-rigger-mistakes (cherry-picking, I know)

Having said that, I would like to see some of the more interesting mistake photos from your collection.

P.S. Current regulations aside, I'm curious whether you would be in favor of allowing senior riggers to perform more work legally, such as relines, on their own gear, in the same way that non-riggers are allowed to pack their own main for the next jump?

[Top_Bunk 0]

Just to throw even more conflicting info out there, look at page 7-31 in the 2015 FAA Parachute Rigger's Handbook:

[inline Main_Line_Replacement.png]