Opening and reclosing other peoples reserve pack jobs

[rigger_john 0]

Hi, at a recent riggers meeting in the UK it was reported that a UK jumper had a USPA rigger fit an AAD into his rig. The rigger opened the reserve fitted the AAD and then reclosed the pack. When the jumper got back to the UK the rigger who packed the reserve told him, that his reserve repack was invalid. Because BPA rule state that only the original packer can open a reserve to add or remove an AAD, change the battery or adjust the loop length ect. If it is done by another packer the reserve must be subject to a full inspection and repack.

Those are the rules in the UK, my question is did the USPA rigger break any rules?

As I understand it the FAA rules say that foreign equipment can be jumped in the USA as long as it meets the requirments of the country it comes from. As soon as the USPA rigger opened the reserve pack job the equipment no longer meet BPA requirments.

Comments and thoughts.

_________________________________________

Nullius in Verba

[riggerrob 643]

You are correct.
I have only put my seal on top of the work of a few other riggers. These were riggers that I had worked with for years and trusted implicitly.

[councilman24 37]

First, there is no such thing as a "USPA rigger". USPA does not regulate or certify riggers. The United States Federal Government through the Federal Aviation Administration regulates and certifies parachute riggers.

There is great debate in this country over whether the practice you described is appropriate. Many of us believe that no matter what may be noted on the card (Battery change only) if your seal is on the rig (I know, no seals in UK) then you've taken responsibility for the entire assembly. Others believe that it is ok to open another's pack job and tighten a loop or change a battery.

We don't have adequate guidance on "legal" and we certainly have differing opinions on whether it's ethical or appropriate.

The section in the LAW, not rules, about this is as follows

Sec. 105.49 Foreign parachutists and equipment


(a) No person may conduct a parachute operation, and no pilot in command of an aircraft may allow a parachute operation to be conducted from that aircraft with an unapproved foreign parachute system unless--


(1) The parachute system is worn by a foreign parachutist who is the owner of that system.

(2) The parachute system is of a single-harness dual parachute type.

(3) The parachute system meets the civil aviation authority requirements of the foreign parachutist's country.

(4) All foreign non-approved parachutes deployed
by a foreign parachutist during a parachute operation conducted under this section shall be packed as follows--


(i) The main parachute must be packed by the foreign parachutist making the next parachute jump with that parachute, a certificated parachute rigger, or any other person acceptable to the Administrator.

(ii) The reserve parachute must be packed in accordance with the foreign parachutist's civil aviation authority requirements, by a certificated parachute rigger, or any other person acceptable to the Administrator.

MY interpretation is that the jumper was violating the regulations by jumping the rig after the AAD was installed because it no longer met 3.

Even inspite of (4)ii the rigger may have done nothing illegal. The rig may not have been airworthy under this regulation, and if the rigger maintained it was he may have been wrong. But the in general it's the responsibility of the user to keep his rig "legal". In this case following BPA rules. It depends on who the responsibility is assigned to and that is not clear.

Certainly what the rigger is may be ethically wrong. But we also don't have a mechanism in this country for riggers to easily find out the requirements of other countries. This came up at the last PIA Rigging committee meeting and may be taken on as an action item to try to maintain references for U.S. riggers to use when working on foreign gear.

PIA Rigging Committee Chairman (which means I'm stupid enough to volunteer)

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[Hooknswoop 19]

1) USPA does't/can't issue rigger's certificates, only the FAA can.

2) There isn't anything in the FAR's that says you can't, IF you sign the card and take credit/responsibility for the reserve pack job from that point. You cannot just open it, put in an AAD, and re-close it without signing the card and noting any work done.

3) What if the rigger that opened the rig and put the AAD in packed a total mal when he re-closed it? Who would the FAA go after since the guy that packed the total wouldn't have his certificate or name anywhere on the card?

I have had another rigger do that to one of my pack jobs and I was pissed about it.

Derek

[rigger_john 0]

Ok sorry about the USPA rigger statment, here in the UK the BPA issues rigger certificates, because the CAA realised along time ago they didn't know enough about rigging to issue them, in fact all parachuting activities aree controled by the BPA on behalf of the CAA.

As for the FAA rigger not doing anything wrong are you saying that it's ok for a FAA rigger to put the AAD in, then release back to the jumper, who then carries the responsibility to ensure that the rigger hasn't broken any rules in doing the work?

FAA riggers can allow a parachute to be given back to the jumper packed and "apparently" ready to jump, but in violation of FAR 105.49 (4) (ii) and it's the foreign jumpers responsibility with no combacks on the rigger who did the work?

Really?

_________________________________________

Nullius in Verba

[Hooknswoop 19]

Quote

As for the FAA rigger not doing anything wrong are you saying that it's ok for a FAA rigger to put the AAD in, then release back to the jumper, who then carries the responsibility to ensure that the rigger hasn't broken any rules in doing the work?

It is an FAR violation to work on a reserve canopy or container and not log the work. So if the rigger opened the reserve, installed the AAD and didn't log it on the card and in their logbook, they are in violation of the FAR's.

Derek

[councilman24 37]

Quote

As for the FAA rigger not doing anything wrong are you saying that it's ok for a FAA rigger to put the AAD in, then release back to the jumper, who then carries the responsibility to ensure that the rigger hasn't broken any rules in doing the work?

FAA riggers can allow a parachute to be given back to the jumper packed and "apparently" ready to jump, but in violation of FAR 105.49 (4) (ii) and it's the foreign jumpers responsibility with no combacks on the rigger who did the work?

Really?

Really? I don't know.

What Derek said is true, the work must be logged. But, I'm not sure if the rigger didn't follow the BPA rules, and tells the jumper he's good to go, he's violated the FAR.

"The reserve parachute must be packed in accordance with the foreign parachutist's civil aviation authority requirements, by a certificated parachute rigger, or any other person acceptable to the Administrator. "

This is very much like the paragraphs that require an pack within 120 days. It's not the rigger's responsibility to make sure that rig comes back and get's packed, it's the users responsibility to ensure it's in date. This allows a U.S. rigger to pack the rig for use in the U.S., even though he may not meet the "foreign parachutist's civil aviation authority requirements" (i.e. have a BPA rating) So obviously not ALL of the foreign requirements must be ment. I'm just not sure how an inspector would interpret this. They very well may have had only the repack cycle in mind when writing this.

This section really applies to the jumper and the pilot. The rigger regulations are in another section. So I don't know if this puts the responsibility on the jumper or on the rigger to know the foreign requirements.

Now any conscientious rigger would not knowingly do this, but again we have no good way of knowing the foreign requirements. The one who knows those best is the foreign jumper.

Obviously the rig was not legal back in the U.K. But I'm still not sure the rigger violated the FAR's or the jumper and pilot did. Or perhaps no one did, since the action performed is legal in the U.S. MY interpretation would be that the jumper and pilot MAY have violated the FAR and the rigger didn't, when the paragraph is read in context. Part 65 which regulates riggers (versus Part 105 which regulates jumping and the equipment used) is mute on foreign equipment.

Unfortunately we have many situations where the FAR's can be interpreted differently, ARE interpreted differently by FAA inspectors as well as riggers, and the FAA chose either not to clarify or takes substantial time to clarify.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[nicknitro71 0]

Quote

Unfortunately we have many situations where the FAR's can be interpreted differently, ARE interpreted differently by FAA inspectors as well as riggers, and the FAA chose either not to clarify or takes substantial time to clarify

So true. Unfortunately the FAA has bigger fish to fry.

As for the original post if it happened to me I would have repacked it just for a piece of mind, laws or no laws.

Memento Audere Semper

903

[rigger_john 0]

I think Terry and others have given well thought out replies to my question(s) Over here in the UK it's a total NO NO to open anybodys eles reserve repack without a full inspection and repack, but we have "grey" areas in our rules too.

_________________________________________

Nullius in Verba

[councilman24 37]

Many of us would like it to be the same here. But, we have another group of independant colonialists who want to be able to do what they want when. And it does serve the customer better if the rigger at the DZ that day chooses to tighten the loop, etc. It may actually serve safety to some extent in terms of not delaying needed work.

At one time Ronald Reagan, when President, proposed deregulating skydiving and rigging (hmm I think both) with the exception of how skydiving integrated with other air traffic. We (the industry in general) protested that mediocre regulation was better than anarchy. No other non governmental group would have the force of law, there could or would be competing standards, and the general safety would have been compromised. USPA was not in a position to take over the regulation, even to a voluntary standard.

We sometimes still debate whether we should try for self regulation beyond what we have. Student training, licenses, etc. are NOT regulated by the government but are self regulated through USPA. In general if we're not killing people we're left alone.

Many times people have proposed revisions to Part 65, the part dealing with riggers, to bring it into the modern age. But, we are often warned off. Friendly FAA inspectors tell us that if we can live with what we have without killing people, leave it alone because we may not like what would be imposed on us.

At some point we are going to have to move forward, maybe. PIA, with the adoption of TS 135 and it's submition to the FAA as the new TSO standard to replace 8015 and with the adoption and editing of many of the parachute related mil specs to PIA specs, is becoming a larger player in the U.S. We also, in the rigging committee, have a project to try to propose standard rigger regulations that other countrys might use as a model, rather than using the poor current FAA regs. But whether we really want people who know what they're talking about regulating us in the U.S. is a huge debate.

And of course in the U.S. we know how much the FAA cares by their unwillingness to issue manditory airworthiness directives (with the force of law) for parachutes even when the manufacturer wants them to. As I have understood the reasoning, the FAA has decided that parachutes are not aviation appliances and they can't issue AD's for anything that isn't an appliance. Of course it's pointed out that only appliances need (can?) be TSO'd so does that mean that parachutes don't need to be TSO'd anymore? Not likely, but shows the inconsistency.

At times I here about the regulations of the BPA and am glad I don't jump there. At other times I wish for the stricter regulation.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[tombuch 0]

Quote

The section in the LAW, not rules, about this is as follows

Sec. 105.49 Foreign parachutists and equipment

(3) The parachute system meets the civil aviation authority requirements of the foreign parachutist's country.

That assumes the rig is actually unapproved. If both the harness/container and the reserve are TSO'ed, then it must be packed by an FAA rigger for use in the United States. If either component is not approved, then it must comply with the home country regulations. See http://www.dropzone.com/cgi-bin/safety/detail_page.cgi?ID=96 elsewhere on this site for a deeper discussion.

My understanding is that the rig was unapproved because it was jumped in the USA as packed by a nonFAA rigger, thus the home country rules apply.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

[sunshine 2]

I've done it. I called the rigger that packed the reserve and told him i was just putting the cypres back in and asked if he was ok with me putting my seal on his pack job. I know i didn't have to ask permission of him, but i thought it was the courteous thing to do.

___________________________________________
meow

I get a Mike hug! I get a Mike hug!

[Hooknswoop 19]

That is completely different from opening a reserve, installing an AAD, closing it, and then giving it back with nothing noted on the reserve card and no seal.

Derek

[fcajump 164]

Terry has address the legal side of the FAA in the US. As to how US rigger feel about it, I would say that I would be pi$$ed off to find out that this happened under my seal...

Locally most riggers seem to believe in not tampering with someone else's pack job enough that they will not even tighten a Reflex loop unless they either were the one who packed it, or they have a specific agreement with the rigger who did.

JW

Always remember that some clouds are harder than others...

[johnny1488 1]

I would say there is definetly no reason to call the previous rigger, its your name on that packjob. You are taking the "risk", not him/her.

Johnny
--"This ain't no book club, we're all gonna die!"
Mike Rome

[councilman24 37]

Derek,

Nobody has claimed that the work wasn't noted on the card. You've assumed that. Of course no seal is following the BPA rules.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[Hooknswoop 19]

You are right, because they didn't say that the rigger wrote anything on the card, I assumed they didn't. Of course for it to be correct, the rigger had to note the AAD and the inspection and re-pack.

To the original poster, did the rigger write anything on the card and if yes, what?

The case where someone re-closed my pack job, the rigger didn't write anything on the card.

Derek

[riggerrob 643]

CSPA policy is quite clear on this issue.
If a Canadian rigger opens a reserve - packed by another rigger - to change Cypres batteries, etc. he has to sign for that entire rig (reserve, AAD, harness and container) being airworthy.
Since few Canadian riggers have that much faith in their colleagues, most will insist on a full inspection and repack before sealing the ripcord and signing the card.
... and CSPA riggers always write (reserve and AAD) maintenance on the reserve packing data card.

[rigger_john 0]

Quote

To the original poster, did the rigger write anything on the card and if yes, what?

The case where someone re-closed my pack job, the rigger didn't write anything on the card.

Derek

They did note on the card that they had fitted the AAD. But my point was as soon as they did so without a full inspection and repack the rig nolonger meet BPA requirments. Therefore using it was a violation of FAR 105.

As for sealing of reserves (sombody mentioned that) in the UK it's the riggers choice to seal or not. Most of us choose not to. I don't unless I'm asked. I don't know of a single case of a seal saving anybody, but I know of one case of it killing a jumper.

_________________________________________

Nullius in Verba

[Hooknswoop 19]

In the US, if he noted it on the card, then he takes responsibility for that reserve pack job and the previous rigger is 'off the hook'.

Derek

[mjosparky 4]

Quote

I know of one case of it killing a jumper.

I would like to hear more about this.

Sparky

My idea of a fair fight is clubbing baby seals

[rigger_john 0]

It happened in Norway some years ago, the seal jammed between the edge of the grommet and the loop, it pinched the loop tight against the grommet so the reserve stayed closed.

As a result of this we changed the way we seal in the UK. Our seals are tacked down so they can't move, we also route the sealing thread a diffrent way to FAA riggers, so it doesn't add any poundage to the ripcord.

_________________________________________

Nullius in Verba

[fcajump 164]

Quote

It happened in Norway some years ago, the seal jammed between the edge of the grommet and the loop, it pinched the loop tight against the grommet so the reserve stayed closed.

As a result of this we changed the way we seal in the UK. Our seals are tacked down so they can't move, we also route the sealing thread a diffrent way to FAA riggers, so it doesn't add any poundage to the ripcord.

(from the US) I've been advised to keep the seal as high on the pin as possible to keep it clear of the grommet for this reason.

If you get a chance to post a diagram, I would love to see your method of placing the seal.

JW

Always remember that some clouds are harder than others...

[masterrig 1]

I won't do it! Over the years, I've seen things that I would not want my 'name' on. I inform folks that if, I did not pack it and they want their Cypres put back in their rig, it's going to be a full I&R. Otherwise, they can take it to the rigger who packed it.


Chuck

[Hooknswoop 19]

Quote

we also route the sealing thread a diffrent way to FAA riggers, so it doesn't add any poundage to the ripcord.

I would be VERY interested to learn more about this method.

Derek