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gnstuff4me

Rigger?

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not for your own main parachute.
IIRC the 3 categories of people who can pack a main in the US of A would be :
a certificated parachute rigger with the appropriate rating
any person under direct supervision of a certificated parachute rigger with the appropriate rating
the person who is going to jump the parachute

The wording might be a bit off, but the general idea is something pretty close.
scissors beat paper, paper beat rock, rock beat wingsuit - KarlM

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not for your own main parachute.
IIRC the 3 categories of people who can pack a main in the US of A would be :
a certificated parachute rigger with the appropriate rating
any person under direct supervision of a certificated parachute rigger with the appropriate rating
the person who is going to jump the parachute

The wording might be a bit off, but the general idea is something pretty close.



Pretty f'n close to the exact wording!

ETA: Also, there's no 'appropriate rating' for packing mains... Just needs to be a certificated rigger. There was a DZ that I remember hearing about would put all of its packers thru a riggers course packing 20 chest packs (with no springs) and get them their chest ticket, so they can legally pack tandem mains. ;)

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(a) The main parachute must have been packed within 180 days before the date of its use by a certificated parachute rigger, the person making the next jump with that parachute, or a non-certificated person under the direct supervision of a certificated parachute rigger





You do have to become a rigger to pack your own RESERVE parachute, though.
"I may be a dirty pirate hooker...but I'm not about to go stand on the corner." iluvtofly
DPH -7, TDS 578, Muff 5153, SCR 14890
I'm an asshole, and I approve this message

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so you wouldn't need a back rating to pack/supervise a main packjob into a back ?


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You do have to become a rigger to pack your own RESERVE parachute, though.

or at least become a riglet and pack under supervision of.... :)
scissors beat paper, paper beat rock, rock beat wingsuit - KarlM

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so you wouldn't need a back rating to pack/supervise a main packjob into a back ?


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You do have to become a rigger to pack your own RESERVE parachute, though.

or at least become a riglet and pack under supervision of.... :)


Nope, there's no type rating required for mains.


As for the under supervision packing, no longer legal to go in the air.
"I may be a dirty pirate hooker...but I'm not about to go stand on the corner." iluvtofly
DPH -7, TDS 578, Muff 5153, SCR 14890
I'm an asshole, and I approve this message

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You do have to become a rigger to pack your own RESERVE parachute, though.



Can't you pack your own reserve under indirect supervision of a rigger?

I.E rigger doesn't have to even be in the same room as you?




Or is that false?

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Can't you pack your own reserve under indirect supervision of a rigger?

I.E rigger doesn't have to even be in the same room as you?

Or is that false?



You can pack your reserve all you want, but it's not legal to go in the air.

To be legal to jump, it must have been inspected and packed within the past 180 days by a certificated rigger with the proper type rating.
"I may be a dirty pirate hooker...but I'm not about to go stand on the corner." iluvtofly
DPH -7, TDS 578, Muff 5153, SCR 14890
I'm an asshole, and I approve this message

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Can't you pack your own reserve under indirect supervision of a rigger?

I.E rigger doesn't have to even be in the same room as you?

Or is that false?



You can pack your reserve all you want, but it's not legal to go in the air.

To be legal to jump, it must have been inspected and packed within the past 180 days by a certificated rigger with the proper type rating.



:ph34r:...or a reasonable facsimile of his signature. :P










~ If you choke a Smurf, what color does it turn? ~

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So let's say I pack my reserve under the supervision of a rigger...It is illegal to jump it since I packed it and not a FAA rigger?


Correct. The old wording under FAR 105.43 either allowed it or was ambiguous (I can't remember which right now). The current wording is:

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No person may conduct a parachute operation using a single-harness, dual-parachute system, and no pilot in command of an aircraft may allow any person to conduct a parachute operation from that aircraft using a single-harness, dual-parachute system, unless that system has at least one main parachute, one approved reserve parachute, and one approved single person harness and container that are packed as follows:

(a) The main parachute must have been packed within 180 days before the date of its use by a certificated parachute rigger, the person making the next jump with that parachute, or a non-certificated person under the direct supervision of a certificated parachute rigger.

(b) The reserve parachute must have been packed by a certificated parachute rigger—

(1) Within 180 days before the date of its use, if its canopy, shroud, and harness are composed exclusively of nylon, rayon, or similar synthetic fiber or material that is substantially resistant to damage from mold, mildew, and other fungi, and other rotting agents propagated in a moist environment; or

(2) Within 60 days before the date of its use, if it is composed of any amount of silk, pongee, or other natural fiber, or material not specified in paragraph (b)(1) of this section.

(c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.



No ambiguity there. If they wanted to allow packing reserves under supervision, they would have worded it similarly to section (a).

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The ambiguity is in the conflict between Part 105 and Part 65.125(a)(2) and 65.125(b)(2), which explicitly permit supervision. The rule-making history of Part 65 clearly shows that the intention was to permit supervision under the normal meaning of the term, and not merely supervision for the purpose of qualifying for a rigger ticket. This issue is still pending resolution.

In the meantime, some FSDOs (but not all) treat supervised pack jobs as they would pack jobs done by an unassisted rigger; some FSDOs (but not all) think that "supervision" really means "training" and don't like supervised pack jobs to be jumped.

Mark

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So according to that, you can pack your own reserve under supervision and it is legal?



Other than the debate about the FAA wording & intent (which has leaned towards no supervision), yes. It's like assisting a mechanic to do maintenance on an airplane. The person supervising is fully responsible for the work done and has to sign it off in the end.

A supervised pack job does tend to take much longer to complete than a regular pack job....

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So according to that, you can pack your own reserve under supervision and it is legal?


Mark corrected me on an issue that I thought was resolved with the last update to the FAR. Unfortunately there is still ambiguity. It all comes down to how the FSDO chooses to interpret it. This happens a lot with the FARs. Some riggers choose the conservative interpretation, some choose the liberal interpretation. Most, I think, go with the interpretation that lets them do they things they want to do. Better to ask forgiveness than permission and all of that.

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Mark,

This has been covered in the past and is one of the problems with the AC-105 2D as you already know.

Supervision for main canopies was only added in 2001. before that it was really simple.

Reserves "For Use" had to be packed by a certified rigger and mains had to be packed either by a rigger or the next person jumping the main.

Pretty simple to verify as all that one needs to do is just pick up an original Pointer's Manual with the pre-2001 rule change printed in it....

65.111 states that you have to be a certifed rigger to pack a reserve. there are no "ands", "buts" and etc. to "muddy the waters" so to speak.

This main part of the rule has not been changed in about 45 years BTW.


65.125 (a) 2. and 65.125 (b) 2. both allow supervision, but do not allow supervision "For Use" which is a key phrase.

Caleb Glick (Washington FAA for those who do not know) has covered this several times.
In fact, I will be talking with him later this AM on other matters, but will also point him to this post.
Hopefully he will respond, but I doubt it.

One question though!
What do you as a DPRE, teach with regards to packing reserves under supervision?

....i.e do you tell your students they are legal to jump or illegal to jump?


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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So if you plan on jumping, a FAA rigger must pack the reserve

If you don't plan on jumping a rigger can supervise you packing it.

If you packed under the supervision of a rigger and you jump it, it is illegal.

Are these all correct?

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So if you plan on jumping, a FAA rigger must pack the reserve.


Yes.

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If you don't plan on jumping a rigger can supervise you packing it.


Technically, no. A rigger can supervise only in accordance with 105.43(a) and 105.45(b)(1), which deal with packing main parachutes. Technically, a rigger may not supervise any reserve pack jobs. There is no exception in the regulation for packs that will be used to qualify for a rigger certificate. This is an unresolved issue left from the poorly written 2001 rule change. I make this argument not because I think supervised pack jobs are illegal, but because there are a few folks who insist that the regulations be followed as though there are no contradictions or inconsistencies -- and the logical consequence of such thinking is that all rigger tickets issued since 2001 were obtained without legally supervised pack jobs.

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If you packed under the supervision of a rigger and you jump it, it is illegal.


Might be. I'm still interested in hearing a definition of "supervision" as used 65.125(b)(2). At one time, master riggers were allowed to both supervise and instruct, meaning the FAA thought these were two separate privileges. When one of the two disappeared, it was "instruct" that went away and "supervise" that remained. [url] If the FAA had wanted supervision to be limited to instruction, then it would have been "supervision" that went away and "instruct" that remained. A more reasonable interpretation of "supervise" is the one the FAA uses in every other case: personally observes to the extent necessary, and takes responsibility for the finished product.

Mark

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Hi Mark,

For the most part, I agree with you.

However, since you are now the Chairman of the PIA Rigging Committee it would seem to me that the PIA should develop a position and petition the FAA for clairification and, hopefully, get the PIA interpretation as the official FAA interpretation.

I just wish that PIA would take a much more pro-active/pro-rigger position on issues like this.

You, Mark Lancaster (MEL), Terry Urban, me, and/or whoever can argue this stuff till the cows come home; but ( IMO ) it is only the FAA who has the authority to interpret their own regs, rules, etc.

JerryBaumchen

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Hi Mark,

For the most part, I agree with you.

However, since you are now the Chairman of the PIA Rigging Committee it would seem to me that the PIA should develop a position and petition the FAA for clairification and, hopefully, get the PIA interpretation as the official FAA interpretation.

I just wish that PIA would take a much more pro-active/pro-rigger position on issues like this.

You, Mark Lancaster (MEL), Terry Urban, me, and/or whoever can argue this stuff till the cows come home; but ( IMO ) it is only the FAA who has the authority to interpret their own regs, rules, etc.

JerryBaumchen



Working on it.

Mark

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Technically, no. A rigger can supervise only in accordance with 105.43(a) and 105.45(b)(1), which deal with packing main parachutes.



65.111, 105.43, and 105.45 all state the same exact thing.
1.Mains can be supervised and jumped...

2.Reserves have to be packed by a rigger ..period.

It is pretty black and white there.

65.125 lists a rigger's privileges as below:


65.125 Certificates: Privileges.
top
(a) A certificated senior parachute rigger may—

(1) Pack or maintain (except for major repair) any type of parachute for which he is rated; and

(2) Supervise other persons in packing any type of parachute for which that person is rated in accordance with §105.43(a) or §105.45(b)(1) of this chapter.

(b) A certificated master parachute rigger may—

(1) Pack, maintain, or alter any type of parachute for which he is rated; and

(2) Supervise other persons in packing, maintaining, or altering any type of parachute for which the certificated parachute rigger is rated in accordance with §105.43(a) or §105.45(b)(1) of this chapter.

Again, pretty black and white.


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This is an unresolved issue left from the poorly written 2001 rule change.



Three things changed in 2001.

1. the tandem inclusion that allowed two people to jump from a single reserve and main.

2. The allowance of supervised main pack jobs.

3. the screw up that included the word "alter" in 65.111 that was later removed.

The rest of the rules stand intact prior to the 2001 amendment.

Check it out, word for word, pre-2001 and post 2001 versions and you will find them to be exact with regards to rigger's privileges.

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make this argument not because I think supervised pack jobs are illegal, but because there are a few folks who insist that the regulations be followed as though there are no contradictions or inconsistencies -- and the logical consequence of such thinking is that all rigger tickets issued since 2001 were obtained without legally supervised pack jobs.



Since there were no changes to rigger's privileges, that theory does not hold water.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Ok, to make sure I understand this...

In order for a reserve pack job to be Airworthy (legal to jump) it must be done by an appropriately rated rigger (not supervised by).

But a rigger may supervise a reserve packjob for training purposes, so that the person being supervised can meet the requirements to get the rating. And while that supervised packjob can be logged and counts toward rating requirements, it is not airworthy (and not legal to jump).

I have to admit that these nuanced interpretations of the regs get very nit-picky, but are kinda interesting.
"There are NO situations which do not call for a French Maid outfit." Lucky McSwervy

"~ya don't GET old by being weak & stupid!" - Airtwardo

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Yes, similar to major airframe maintenance. Apprentices are able to have work looked over in a shop for it to count towards their learning but you can't just have a non rated person do a rebuild on an engine and have and A&P sign off on it with out having done the work themselves legally.
Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

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Hi joe,

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I have to admit that these nuanced interpretations of the regs get very nit-picky, but are kinda interesting.



IMO only the FAA can 'interpret' their own regs.

The rest of us, including me, can only give our opinions on what they mean.

And even the FAA can be over-ruled should something go to court and get a judge's ruling.

Just my $0.02,

JerryBaumchen

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