Who Modified My rig IS THAT LEGAL?

[billvon 2,426]

>It was not an update. and to my understanding Service bulitens do not have to be
> complied with unless you want to. to my knowledge there is no service bulitin on
>this rig anyway.
There are different levels of service bulletins. Advisory or optional ones do not need to be complied with; mandatory ones do. Look at the Precision and the Rigging Innovation websites to see examples of all kinds of service bulletins.
>Airworthyness Directives from the FAA have to be complied with.
Agreed, but keep in mind that aircraft and parachutes are certified under slightly different systems, with different paperwork requirements and different considerations (i.e. riggers vs A+P's)
> . . . what gives Them the right to chop it out without my knowledge?
Again, they have the right in the FAA's eyes to do whatever they want to the rig. From a customer service viewpoint they should have at least let you know.
>Does Rigger know what FAR governs rigs and who can do what to who's rig?
FAR part 65 discusses what riggers can do; it does not discuss rig certification and modification though. That's not in the FAR's.
-bill von

[Unisyn 0]

As a parachute/container manufacturer we are responsible for the safety of our product, and in accordance with FAA regulation have the right to modify or require mods to be made to that product. The secondary closing loop attachment found on Mirage harness/container systems built between April 1997 and December 1999 have an adequate design but Mirage Systems PREFERS them removed. Since many riggers do not have the skills to properly remove the secondary closing loop attachment we do the work in house. Containers that we receive for repair that have the secondary closing loop attachment have had it removed to ensure the safest rig possible.
As for this specific case, Mirage Systems customer service and technical department have been in contact with the customer. It was determined that it was a primarily a down sizing issue and a slight misunderstanding.
Mirage Systems, like many parachute manufacturers, have the customers safety as it's number 1 priority. If a skydiver has a question or is upset with a product or service the FIRST and foremost authority is the manufacturer. If you are not getting the answers that you deserve then by all means Dropzone.com is the place to post your veiws.

[polarbear 1]

I believe Advisory Circular (AC) 105-2C gives a little clarification on who can do what to a container. However, from what my rigger studies are telling me, billvon is right. The manufacturer CAN modify the rig. If the modification is done to the reserve container or harness (the TSO'd part), it might (probably will) neccesitate FAA approval, depending on if the modification is different from the TSO drawings. If it is done to the main container, approval is not needed.
I would agree that no one should do ANYTHING to your equipment (except maybe comply with a mandatory AD)without talking to you about it first, or at least letting you know what they did and why. The manufacturer may have legal backing to do something, but they should respect ownership of property.

[riggerrob 558]

That whole "respect property ownership" is a dicey issue in a sue-happy capitalist society.
On the one hand, a manufacturer is not allowed to destroy unairworthy gear, but on the other hand, a manufacturer can be sued because of worn out gear.
Several times when faded, frayed and filthy old Talons came through the Rigging Innovations loft, my first instinct was to chop them into little bits and send the owner a letter saying that his rig was no longer airworthy. I was motivated by the notion that not all skydivers are bright enough to heed a manufacturer's warning about gear being worn out.
The other problem is that in a capitalist economy, there is always one more dis-reputable rigger farther down the road. If a skydiver searches long enough and hard enough he can find a rigger who will pack anything. Ironically it is rarely young jumpers who play this weird game. More often it is penny-pincing older skydives - the type that make "Air Trash" look good - who know that rigger at the end of the road.
In the end I compromise and offer to do hundreds of dollars worth of repairs to ratty rigs, or try to steer them towards inexpensive, airworthy gear. In the end, I return one or two rigs a year, dis-assembled, with a signed note saying that I refuse to repack them because of the following defect. Hopefully the note will cover my butt if I ever get called into court.
Thanks for reading my rant.

[billvon 2,426]

>However, from what my rigger studies are telling me, billvon is right. The
>manufacturer CAN modify the rig . . .
OK, I did some more research, and I found something that may explain the perception that manufacturers cannot modify their own gear. Here's what I came up with:
First of all, there is an odd loophole in the law. The FAR's spell out who can modify a rig, and list which types of riggers can perform which sort of maintenance/modification. They do not explicitly say that the manufacturer can do it. This is interpreted differently by different people - some claim that the intent is to allow the manufacturer to perform maintenance on a rig, some claim that you have to be a rigger to do any mods at all.
This pops up very rarely. When the FAA was doing an inspection on a certain rig manufacturing company about ten years ago, one of the inspectors said "But you can't get rigs back and fix them - you need to be a rigger to do that!" The manufacturer opened a door and said "Well, there's our loft, and the guy working in there is a rigger." Case closed.
So if there is a master rigger working for the manufacturer (and it's very rare that that is _not_ the case) then the rigger can legally do any approved minor modification to the rig. What's an approved minor mod? According to CFR title 14 part 21.605:
"When a series of minor changes in accordance with § 21.611 is anticipated, the applicant may set forth in its application the basic model number of the article and the part number of the components with open brackets after it to denote that suffix change letters or numbers (or combinations of them) will be added from time to time. "
This, of course, applies only to the part of the approved article that is covered by the TSO. In the case of at least one manufacturer, that does _not_ include the main container, so any modification to the main container doesn't even fall under the above restriction (according to that manufacturer at least.)
Wading through the CFR's (Code of Federal Regulations) is a pain in the butt, and if anyone wants to do it take a look at either http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_14/14cfr21_00.html or http://www.access.gpo.gov/nara/cfr/waisidx_02/14cfr21_02.html. The applicable parts are title 14 (aeronautics and space) part 21 (certification procedures.)
-bill von

[polarbear 1]

I'm not neccesarily talking about SUEING anybody. The fact is that when you pay $1000-2000 for a container, it becomes yours. The manufacturer DOES NOT own it. They have a legal right to declare it unairworthy, or to to demand that a modification be made to it to make it airworthy (issue an AD), or to not pack it/fix it if it comes in the shop if they think it is unairworthy. If they want to recommend a modification be made, fine. That's all cool (it would suck if it happened, but it goes with the territory). Personally, I welcome the input of the manufacturers. I am also glad to know that there are people out there who will bite the bullet and say old ratty gear is no good anymore.
But to make a modification, especially one that DOES NOT affect the airworthyness, without even consulting the owner is overstepping the bounds, at least in my book.

[DiverStump 0]

I did post a note before saying thank you for all the advice and input from the riggers especially Bill Von and that the manufacture of the rig had contacted me and was making a genuine effort to make me happy and fix the problem. I don't know why it didn't post...
I do want to say again thanks for all the help. I am still unhappy with the way I wasn't contacted. However they (Mirage which you now know who it is because of unisyn's response to my thread) has called me and we are talking about how to fix the current problem.
Skydiving is a sport where we all take risks and we all sign waivers saying we understand those risks. All the manufactures of skydiving gear have there own little way of covering their asses for example some of the helmets I have seen say they are not intended for skydiving even though they are built for and marketed to skydivers. So in a sport where we cant say hey my gear didn't save me from getting broken, I'd like to at least be able to say, " This is my gear please respect that and me with a phone call or email"
And just a little side note.... This is the best rig I have owned it is comfortable reliable and sturdy. I have owned 3 and currently own 2 but I really only Jump the Mirage unless I'm trying to pack 'em in at a boogie. If I were to buy another rig I would still want a Mirage!