petition for exemption to the 120 day reserve repack cycle denied

[jsaxton 0]

RECEIVED ON THE NCS EMAIL LIST
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Hi all,

As you've likely heard, there has been a petition for exemption of the120 day repack rule filed by Alan Silver of behalf of PIA and other interested associations.

I recently visited the Parachute Industry Association (PIA) website, I learned that the FAA has responded to the petition.

Unfortunately, the response, though not entirely negative, is not what we were hoping for.

The entire response is available at:

http://dmses.dot.gov/docimages/pdf92/342065_web.pdf

The meat of the response is (this is an excerpt from the complete
response):

Except on very rare occasions, the Federal Aviation Administration (FAA) does not issue exemptions to groups as large as those you have proposed in your petition. An exemption,
if granted, could conceivably affect the majority of the regulated
people who use approved parachutes. We find our rulemaking process, rather than the exemption process, is a more appropriate method to address issues affecting large groups of

regulated people.



To that end, we will initiate a rulemaking project within the
next few months to develop a notice of proposed rulemaking (NPRM). Using the NPRM, we will ask for comments from
interested people on a proposal to lengthen the packing interval
for approved parachutes. We believe this approach will enable us to analyze the merits of your petition and to reexamine
the issue of parachute packing intervals.



So, it will surely be quite a while before we see any change to the
current 120 day reserve repack cycle.

-paul
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[grue 1]

God, that sucks. Typical "the rest of the world isn't as good as us, we'll do it our way or no way at all" governmental behaviour.

cavete terrae.

[slotperfect 7]

If I'm not mistaken, exemptions have to be renewed periodically (like the tandem exemption before tandem jumping was included in FAR Part 105).

So, it can be looked upon as not so bad news - if and when the FAR gets rewritten to read 180 days it will not need to be renewed.

Arrive Safely

John

[skymedic 0]

that's exactly right John...problem being it'll take a couple of years before it gets rewritten.

Marc
otherwise known as Mr.Fallinwoman....

[skydivingdutch 0]

Maybe we can try again in a few months with the new rule making process, and this time go for a the full year repack cycle. Reserves have opened just fine that have been packed for years with no problem

http://dropman.com

[kosanke 0]

looking back, i think you will find that the CAA,the FAA of the time, made the wright brothers go back and seek approval from the bike manufacture on the use of chain in a manner it was not designed. they would have been flying 2 years earlier had not the government stepped in to give some help.

[airtwardo 7]

Just wondering your thoughts John...

Might they consider making it a 'special' class for dual parachute systems?

From what I understand anyway, the concern is more with single parachute systems that are not as well 'cared for' as a skydivers rig.

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

[Hooknswoop 19]

Might want to check your history:

Birth of Aviation
The Wright Brothers made the first powered flight in a pilot controlled aircraft on December 17, 1903. The flight was the first to experience weather delays - the original date for the flight was December 14.

1919 - President Wilson proposes that the Commerce Department license pilots, inspect and register aircraft, and supervise the use of airfields. Congress took no action on his proposal.

1923 - Light beacons are added to the Transcontinental Air Mail Route between Chicago and Cheyenne, allowing night flights.

1924 - regular scheduled flights are started along the Transcontinental Route.

1925 - The Kelly Air Mail Act puts the Post Office out of the flying business. Specific segments of the air mail routes are put out for bid. The early airlines are formed as contract mail carriers.

1926 - The Air Commerce Act is passed by Congress and signed into law by President Coolidge. Then Secretary of Commerce Herbert Hoover creates the Aeronautics Branch to handle these new responsibilities. Its first budget - $550,000!

Or were you being sarcastic?

Derek

[councilman24 37]

This is not a negative.

While the request for an exemption was denied, it would have been burdomsome on the industry to report data. The FAA is initiating the NPRM. While this will take somewhat longer to enact if ultimately approved, it will be permanent and not require data accumulation and reporting.

This is a good thing, (oh puck I sound like martha stewart.) The concensus from those dealing with the feds on this at the PIA business meeting is that this WILL be a reality in the near future. We will be following up to make sure the process is moving.

Chairman, PIA Rigging committee.

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

[slotperfect 7]

Quote

This is not a negative.

I agree.

I sure like "there is a plan, albeit a slow one, to make 180-days permanent" better than "we are working on it."

Arrive Safely

John

[FrogNog 1]

I don't think that kind of humor could be called "sarcastic". It was more deadpan surrealism.

-=-=-=-=-
Pull.

[kosanke 0]

sarcastic? the first step is to realize that i do have a problem. i've hit bottom.
all sarcasim aside, i do feel that the FAA has not done all it could to correct and update to current standards.

[NickDG 23]

I agree with Jimbo. Pilots treat parachutes horribly and most consider them just a nuisance. You see rigs years out of date, you see them hanging from nails on hangar walls or piled in a heap in the corner. They often get drenched in sweat and left inside aircraft to bake on the flight line.

I remember one pilot rig years ago that passed from pilot to pilot for a few years without benefit of rigger intervention before a glider pilot was forced to use it. He died as the rig was essentially field packed with the lines daisy chained.

Yes, they should up the repack cycle on sport rigs, but pilot rigs should probably go back to 60 days . . .

NickD BASE 194

[riggerrob 643]

Quote

sarcastic? the first step is to realize that i do have a problem. i've hit bottom.
all sarcasim aside, i do feel that the FAA has not done all it could to correct and update to current standards.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

Let's keep this in perspective.
Skydiving represents less than 1% of the FAA's business.
They have far more pressing issues to keep them busy: Al Queda, flooding in New Orleans, etc.
The FAA's general attitude is that the current repack cycle produces a tiny fatality rate, so why change something that is working?
The other problem is that a 180 day repack cycle is not safe as a NATIONAL standard. 180 days may be realistic for Wisconsin, but is foolish for Southern California.
We all know that reserves open just fine after they have been sitting on the shelf for a year or three, but htat is not the point. Maintenance cycles are written with the goal of discovering cracks, corrosion, wear, tear, etc. before they become life threatening.
For example, we know that rubber bands start to rot after two years in the California desert, so the FAA will never legislate a 2 year repack cycle.
And since the longest cycle on privately owned airplanes is annual inspections, the FAA will never approve an inspection schedule longer than 1 year.

In conclusion, a 180 day repack cycle only works well at DZS that jump 5 or 6 months out of the year and the average jumper makes 50 or 100 jumps per year. More jumps than that per year requires more inspections.
Don't get me going on that subject, as I believe that school and rental gear should be on a 100 day repack cycle, but that complexity would boggle the mind of an FAA Inspector.
Hah!
Hah!

[tombuch 0]

Quote

In conclusion, a 180 day repack cycle only works well at DZS that jump 5 or 6 months out of the year and the average jumper makes 50 or 100 jumps per year. More jumps than that per year requires more inspections.
Don't get me going on that subject, as I believe that school and rental gear should be on a 100 day repack cycle, but that complexity would boggle the mind of an FAA Inspector.
Hah!
Hah!

A shorter cycle for students shouldn't boggle an inspectors mind at all. It's simply a matter of defining private use vs. commercial use, something that is already done with airplanes. Privately owned parachutes used by the owner should be on a 180 day cycle. Parachutes used by students, or in rental/loan programs should be on a shorter cycle so that a rigger inspects the equipment more often.

The exemption request was filed on behalf of many organizations representing 620,000 users. Nobody is speaking for the students, passengers, or other members of the general public that don't belong to one of the big alphabet groups.
.

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

[airtwardo 7]

They often get drenched in sweat and left inside aircraft to bake on the flight line.

***

Exactly...

Some use really old, marginal, not maintained rigs
that they barely know how to put on much less take care of.

That's where the regulation needs to be focused.

Not on a group that understands the necessity
of keeping something they know very well they
may need TODAY... in working order and up to date!

We're in a very different game, we should have separate rules.

IMHO anyway....

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

[skymedic 0]

Quote

but pilot rigs should probably go back to 60 days . . .

I have seen this same thing that your talking about...horribly treated pilots rigs...sitting out in the sun in some T34's that I used to fly with. sun damage that was unbelievable. let alone packed properly...or in date.

BUT since they don't follow the current pack cycle what makes ya think they'd follow the 60 day pack cycle??

seems that the ones that follow the pack cycle are the ones that are involved in airshow's...as they HAVE to show there in date there.

Marc
otherwise known as Mr.Fallinwoman....

[jdfreefly 1]

I think it may be a bad idea.

In the last year, two people I know, avid pond swoopers, had to send their reserves in for repairs, one of them quite extensive repairs.

The damage was the result of rust from the grommets on their reserve's sliders.

This was after the standard 120 day repack cycle. How bad might the damage have been after 180 days?

Methane Freefly - got stink?

[tr027 0]

Quote

In the last year, two people I know, avid pond swoopers, one of them quite extensive repairs.

The damage was the result of rust from the grommets on their reserve's sliders.

Yea, that also surprises the heck outta me. I never knew that if you submerged a reserve in pond water that the grommets would rust. This is nothing short of outrageous.

"The evil of the world is made possible by nothing but the sanction you give it. " -John Galt from Atlas Shrugged, 1957

[golowjoe 0]

If these people are avid pond swoopers and are not opening up there reserves after are hard weekend of geting your stuff completely submerged in water and don't understand the difference than those idiots deserve what they get . Do you think your equipment is indestructable under those conditions ? That is the price we pay as swoopers for doing what we love . If you can't take better care of your stuff than that , then maybe they should get out of swooping .
As far as the pack cycle goes I can't wait for it to go to 180 days . The worse thing we can do is touch the chute . If you know where your chute has been 180 days is plenty safe . If you have a question ask someone who knows . Why does PD say 1 year ? Maybe because it doesn't affect the opening time at all .

[Hooknswoop 19]

Quote

Why does PD say 1 year ?

And what does PD say about completely submerged reserve?

Derek

[billvon 2,989]

>In the last year, two people I know, avid pond swoopers, had to send their
>reserves in for repairs, one of them quite extensive repairs. The damage
> was the result of rust from the grommets on their reserve's sliders.

And secondarily from their failure to maintain their gear.

I could set my rig on fire this weekend then try to jump it the following weekend. Heck, after that, it might not work at all! But that would be a poor argument for a 1 week repack cycle. It's a given (and is covered in the manual) that any time a reserve gets wet, or damage is suspected, it must be inspected and repacked. That won't change no matter how long the repack cycle is.

Personally I think that the regs should say "parachute equipment must be maintained to the manufacturer's requirements" period. We already do that with AAD's, and PD knows their equipment better than the FAA does.

[CReWLL 0]

Everyone that wants a 180 day repack is interested in saving money on repacks, not in the parachute condition. You could save a lot on money on a new car, but the damn government demands airbags, seatbelts and all sort of other expensive equipment. Ask any airplane owner if they would rather have 10 year inspections instead of annuals.

[GTAVercetti 0]

Quote

Everyone that wants a 180 day repack is interested in saving money on repacks, not in the parachute condition. You could save a lot on money on a new car, but the damn government demands airbags, seatbelts and all sort of other expensive equipment. Ask any airplane owner if they would rather have 10 year inspections instead of annuals.

That does not explain PIA endorsement of it. The Industry would stand to make LESS money if it was implemented.

And what about the other countries that use a 180 (or more) repack cycle? I guess they are totally in danger? we better call England and Australia (just two of many) and let them know!

And the connection to an airplane? I would say an aireplane is a MUCH more complicated piece of machinery and yet they only have a yearly inspection. Seems like an airplane should go to 120 days.

Why yes, my license number is a palindrome. Thank you for noticing.

[ryoder 1,590]

Quote

Everyone that wants a 180 day repack is interested in saving money on repacks, not in the parachute condition. You could save a lot on money on a new car, but the damn government demands airbags, seatbelts and all sort of other expensive equipment. Ask any airplane owner if they would rather have 10 year inspections instead of annuals.

And I would oppose a 10 year repack cycle for the same reason those owners would oppose a 10 year inspection cycle. Now ask those owners if they would prefer inspections every 90 days.

"There are only three things of value: younger women, faster airplanes, and bigger crocodiles" - Arthur Jones.