SSK

good question! what you are referring to is SSK's default procedure unless instructed otherwise by the rigger (most of the time it does not make sense to have the extra repack cost to squeeze out another couple months of battery life), but if you have a specific request or need, just talk to Eric at SSK - you can even send us a replacement battery that you happen to have in stock, it will be installed at no charge the paperwork (invoice that goes to the rigger, and test certificate that goes to the owner) state the battery replacement date, battery due date, and next maintenance due date info the good news is that with CYPRES 2 there are no battery-change issues to be concerned about! Cliff

Mel, help me out here, I still can not find the regulation that states that the rigger is responsible for the "120 day window" I'm going to assume that you are joking here - because of the variables of repack vs. DOM and of the differing repack requirements around the world, the maintenance windows, due dates, and lifetime would have to be altered to accommodate the worst case scenario in order to maintain the present level of technical safety we have achieved on the other hand, you could do what you believe is right, and accommodate your customers making sure they do not loose any useful CYPRES life by simply reminding them 120+ days prior to CYPRES due date that you need to I&R their reserve now! Cliff

so, under your interpretation of 105, if a jumper jumps an out of date reserve (past 120 days in the US) the rigger is responsible ?!? where is this specifically stated in the regs? the 12-year lifetime +3 months for CYPRES-1 and +6 months for CYPRES-2 NEVER had anything to do with repack cycles - it is based on 4 years from the 8-year maintenance final due date (meaning there is no disadvantage to doing the maintenance earlier in the window) check my math, but having a 3 month or even a 6 month "buffer" does not mean the AAD would be legal through the entire repack cycle, depending on the timing of the repack and CYPRES DOM and with the 1-year repack cycle in some countries, you are talking about robbing the CYPRES owner of up to 11 months of use! currently in the US with our 120-day repack, a customer could loose up to 3 months of CYPRES use (when we change to 180-day up to 5 months) - for some jumpers, depending on the timing of DOM, repack cycle, and jump season (down-time over winter), you could be requiring your customer to buy a new CYPRES in the middle of the summer instead of sometime the next spring! I totally agree it is your personal choice to handle this the way you want to - however, right now I see nothing in the regs that requires riggers to do so in the U.S. sounds like a good topic for the Rigger's Forum at the PIA Symposium in February! for now, in lieu of any regulations that I am not aware of, our earlier recommendations and requirements remain Cliff

Hi Mel, actually, I am not sure we are really in disagreement agreed - I never suggested to state that the reserve repack was good for less than the standard time (120 days in the U.S.) - my suggestion is that it should be noted that the AAD is no longer airworthy after a specific date - then it is up to the jumper, just like it is up to the pilot of an aircraft - only jump or fly if airworthy - a rigger can help jumpers out by making it easier to determine airworthiness status of a parachute, so they can make the proper determination prior to the next jump - in some countries parachute packing data cards state when things are next due, much easier to determine airworthiness status than stating when last done (and of course, a parachute can become un-airworthy at any time prior to any of the due dates because of other factors which are out of the control of and/or unknown by the rigger at time of repack) agreed, already said our position is that the parachute should not be jumped after the AAD due date agreed, already stated that I believe that this is an issue that is up to the individual rigger and what he feels comfortable with follow the references and read the the various regulations I referred to in my original post - nothing indicates that the rigger is certifying that the parachute is airworthy until the next required repack, and nothing states that the rigger is the "police", and needs to make sure that only in-date parachutes are jumped - according to the regs, this is the responsibility of the jumper and (unfortunately) the pilot (because in the U.S. a parachute is an aircraft "appliance") 105.43(c) drags us into the matter no - remember CYPRES is used world-wide with all the various rigging and repack requirements - the +3 months on CYPRES-1 lifetime came from the +/- 3 months on the maintenance, just like the +6 months on CYPRES-2 lifetime comes from the +/- 6 month maintenance window Cliff

good point Derek, the problem is, if the rig is considered "legal" to jump, someone (possibly other than the owner) could incorrectly assume that all components are currently airworthy using the aircraft analogy, if there were a means to tag the CYPRES "out of service", such that it could be ensured that the CYPRES would not be switched on and that the user was properly informed that the AAD was out of service, it would probably be OK to jump the rig - common practice with certain non-essential aircraft instruments, not sure if it is practical with a rig.... I suspect your point is one of the reasons that a lot of riggers feel uneasy about packing a rig when the CYPRES is not good for the entire repack cycle Cliff

we have no problem with reserves being packed where the CYPRES and/or batteries will go out of date prior to the next required I&R as long as it is properly annotated on the reserve data packing card (AAD no longer airworthy after xx/xx/xxxx) and the customer is properly informed as to what his options are this will become even more of an issue in the U.S. once we get approval here for the 180-day repack cycle - think of the logistics and issues involved in countries where the repack cycle is already 180 days or one year no where in part 65 does it state that the rigger is certifying that the parachute is going to be airworthy until the next REQUIRED I&R - in fact, part 65 does not even refer to the repack cycle! (see parts 105 and 91 for repack requirements) 105.43(b)(1) requires that a reserve used for intentional parachute jumping must have been packed within 120 days before the date of its use 105.43(c) states that any installed automatic opener must be maintained in accordance with manufacturer instructions however, read the preamble to 105.43, it states that no person may conduct a parachute operation ... and no pilot in command may allow ... no where does it mention anything about parachute riggers "allowing" - it just requires a rigger to do the required packing a parachute manufacturer could disallow the packing of a reserve if the AAD would not be in date for the entire repack cycle via the provisions of 65.129(e) - but I know of none who have made this restriction in their manual as riggers, we are stating that the parachute system is airworthy at the time of the I&R - the next day, depending on what happens to the rig (getting dragged across pavement, etc.) it could be un-airworthy and in need of another inspection ref PIA Petition for 180 day repack page 37 (40 of 45): http://dmses.dot.gov/docimages/pdf92/338980_web.pdf there is a lot of precedent for riggers (airmen) from aircraft mechanics (also airmen, and also regulated under part 65) - when the annual is done on an aircraft, that doesn't mean that the prop might not come due before the next annual is due please note that although I am presently serving as President of PIA, I am not speaking on behalf of PIA on this matter - be aware that there are PIA members (riggers) who disagree with me bottom line, I do not believe there are any legal issues involved, but I also believe that this is an issue that is up to the individual rigger, and what he personally feels comfortable with in summary: 1) we have no issue with reserves being packed when the CYPRES (and/or battery in the case of CYPRES-1) will go out of date prior to the next required repack - we DO have an issue with a parachute being jumped if the CYPRES maintenance, CYPRES lifetime, or battery is out of date - and like it or not, in the US 105.43(c) makes it illegal to do so 2) I find no regulation to form the basis that makes it the responsibility of riggers in the U.S. to "enforce" a future airworthiness due date by refusing to pack 3) we suggest that riggers should discuss options with their customers, and properly annotate all airworthiness due dates on the packing data card in other words, to answer Gus's specific questions, yes to both - inform the customer that he will be needing a new CYPRES by a certain date, discuss options, and if appropriate, do the repack and annotation on the data card Cliff Schmucker SSK Industries, Inc.

see PIA Technical Bulletin 200 dated January 10, 1985 for some history on the subject of "plastic" ripcords http://www.pia.com/piapubs/tb/tb-200.pdf - Cliff Schmucker

CYPRES 2 photo and some updated/additional information posted today on the CYPRES 2 site also have received a number of good questions for the CYPRES 2 faq - hope to have the answers posted there tomorrow if anyone else has any specific questions you would like addressed, please email them to [email protected] and we will try to get them on the faq as soon as possible please understand that things are rather hectic at both Airtec and SSK right now - thanks for your patience Cliff Cliff Schmucker

check out www.CYPRES-2.com for this information and more as it becomes available from Airtec - Cliff Cliff Schmucker