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scdrnr

Manufacturer Instructions Mandatory? More Fuel for the Debate

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I just recieved a "Special Airworthiness Information Bulletin" from the FAA on the Omega/Quick groundings.

While I appreciate the FAA sending me this "Urgent: Information Critical to Flying Safely" notice 5 months after it being old news, I am surprised by the language it contains. Right there in bold italics it says: "This is information only. Recommendations aren't mandatory." It then "strongly recommends that you comply" with Performance Variable Service Bulletin SB-0-200501.

Strongly recommends? Recommendations aren't mandatory? Are these the same people who wrote FAR 65.129.

Why should anyone feel legally obligated to pull-test PD reserves, check boxes, remain within TSO weight-speed limits, make width adjustment folds or dress a tail one way or another when the FAA uses such lukewarm language on what is obviously a critical safety directive issued by a manufacturer?

I would contend that the FAA, despite the FAR's, is taking the official position that manufacturer instructions, including SB's, are only recommendations. And recommendations aren't mandatory.

This is similar to the widely held consensus among aircraft maintenance professionals, which is that contrary to FAR 43 and 91, engine TBO's, cycle limits, service intervals (other than annual or hundred hour inspections), and SB's are optional unless you are subject to some kind of operating certificate (ie, 135, 121, etc.) If it ain't an AD (Airworthiness Directive) it ain't required! The FAA seems to agree.

So I guess my point is, why doesn't the FAA just drop all these rules they don't seem interested in enforcing. Riggers and jumpers should spend less time and energy debating what's legal instead of whats safe.

Any thoughts?

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Not sure what your point is. I don't believe the FAA still issues ADs for skydiving equipment. SAIBs are for information only. Without an AD, it's not mandatory.

Not complying with an SB might be in violation of the FAR you mentioned. That's a catch-all. But the SB itself isn't mandatory and an SAIB doesn't make it mandatory, it alerts users/riggers to its existence.

The FAA really isn't the expert on skydiving equipment. I think it's great that they don't issue mandatory directives anymore. They get things wrong too often...

Dave

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Welcome to federal politics and bureaucracy.
Hee!
Hee!
It is all about appearances.
Bureaucrats need some piece of paper that proves that they care.
The FAA must be SEEN to care about all those silly, little, annoying aerosports that create less than 1% of their business.
Somewhere along the way , there must be written proof that the FAA warned skydivers about some obscure maintenance problem, but as long as skydivers don't interfere with airliners, the FAA does not CARE.

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Hey "No Name Entered",

You have some valid points!

AD's take longer to get authorized and published than the Special Bulletins,
and look how long it took to get the bulletin out to us!

Quote



I would contend that the FAA, despite the FAR's, is taking the official position that manufacturer instructions, including SB's, are only recommendations. And recommendations aren't mandatory.



The manufacturer's instructions are "approved" by the FAA as part of the TSO process.They are a requirement.

I think SB's from the FAA's standpoint, are EXPECTED to be complied with rather than REQUIRED to be complied with.

What's the difference? I do not have a clue!

Quote



Riggers and jumpers should spend less time and energy debating what's legal instead of whats safe.




Agreed! But at the same time, riggers and jumpers will continue to go beyond their capabilities (lack of skill and equipment), and some riggers beyond their certificate limitations.


Last week alone I had two canopies that came in with lines installed inside out (wrong).) They were not installed by Master Riggers nor with the proper equipment either.

One customer wanted to know why his canopy suddenly started to fold up in turblence!!!!!!!!!!

So,if you do what your last sentence states, there should be no problem or question.

I think you answered your own question! ;)


Safe Ones,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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I would contend that the FAA, despite the FAR's, is taking the official position that manufacturer instructions, including SB's, are only recommendations. And recommendations aren't mandatory.

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

I am going to respectfully disagree.
The FAA delegates much responsibility to manufacturers' manuals.
A jump pilot got his license suspended (for 6 months) - for lipping off an FAA inspector - but the citation read "failure to have aircraft operating handbook on board." Meanwhile, there was a large stack of genuine DeHavilland manuals under the co-pilot's seat.

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Rob, aren't Airworthy Directives sent to the FAA by the manufacturer ('s) and the FAA only prints and sends-out what the manufacturer ('s) send them? Same with Service Bulletins? In other words, the FAA doesn't just send-out 'their version' of what the manufacturer ('s) want.


Chuck

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ADs are written by the FAA. Sometimes the manufacturer absolutely disagrees with the AD. Same with SAIBs. Service Bulletins come from the manufacturer. Sometimes an SB is made mandatory by an AD if the FAA feels it's necessary.

Dave


______________________________________

Thank you!


Chuck

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Last week alone I had two canopies that came in with lines installed inside out (wrong).) They were not installed by Master Riggers nor with the proper equipment either.



Do you mean they attached the outboard lines in the center, and the center lines to the end cells? :S

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Do you mean they attached the outboard lines in the center, and the center lines to the end cells?



Exactly....The A1's on most canopies are at the stabilizer while the A5's are in the center.

On PD canopies(why they did it like this I do not know) it is reversed with A1's in the center with A5's at the stab.

What happens is probably more riggers have changed out PD line sets than others. They get accustomed to that method. Then they get an Icarus line set and install it without following the directions.

With the line set installed in reverse, the center lines will be longer and the outside shorter, making the canopy very prone to nose inversions.(we are talking mainly Eliptical canopies here)

The short of it is, the canopy could collapse in turbulence very easily if installed incorrectly.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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I would contend that the FAA, despite the FAR's, is taking the official position that manufacturer instructions, including SB's, are only recommendations. And recommendations aren't mandatory.

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

I am going to respectfully disagree.
Quote



Therein lies the problem, two people doing their best to understand come to different conclusions. It shouldn't be this tricky to figure out what the law is.

A jump pilot got his license suspended (for 6 months) - for lipping off an FAA inspector - but the citation read "failure to have aircraft operating handbook on board." Meanwhile, there was a large stack of genuine DeHavilland manuals under the co-pilot's seat. ***

Sounds familiar. ;)

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:)
One more reason that MAIN canopy reline MUST be done by Master Riggers ONLY who have the mfg. spec. & drawings & the ability to perform the work.

When a mfg. line set arrived for reline it must be inspected & the trim must be checked by the trim chart which should be on the mfg. website or should be shipped with the lines.

The chart should show the SETTING (A5, A4 etc.) & the TRIM.

If the Master Rigger does not have the technical info.
he MUST NOT reline the canopy !!!

It's about time that mfg. will create Service Centers based on Master Riggers with the ability to do the work and with the best technical backup from the mfg.

It's about time that riggers will understand that Riggers can not do everything & should understand the ability & certificate limits.

RELINE is a MAJOR repair even on the MAIN !!!

Same rules for MAJOR Patch work on main canopies.

:)and move on step by step !!!

Safe Rigging !!!

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:)
The manual is not an advice, is the way that the mfg. says DO IT by the book which is a part of the canopy TSO.

Same with MANDATORY SB from the mfg. they must be done, they are a mfg. mandatory change to his product TSO.

For us the riggers is - do it !!!

Same for PD packing/deployments boxes & the 30 lb. fabric pull test, they are all a part of the PD reserve manual & must be done by the book & by PD.

Safe Rigging !!!

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Could'nt agree more. Would'nt mind seeing changes such as special ratings for repair work to be attached to the riggers certificate. Such as adding type ratings, must qualify with experience and signed off by person holding such rating. Young rigger had finally talked me into helping them w/linekit for their own main. Helped young rigger make and install lineset for their own main one time (one day)without charging for it, they then became the expert by the next day. They took the expertise for granted. Especially thinking that all it takes is one day, one lineset to become qualified to do such. Seems like linesets are a free for all w/o any sort of ways to qualify.

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Seems like linesets are a free for all w/o any sort of ways to qualify.



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

Hee!
Hee!
FARs are quite clear bout who can replace suspension lines: only Master Riggers.
But skydivers can always find a way around any regulation ... even if it is only in their own mind!
Hee!
Hee!

Considering how much difficulty I had accumulating a hundred different trim charts and learning all the different methods used by different manufacturers (most of which are not written down), it amazes me how cavalier young jumpers are about re-lining canopies.
What amazes me even more is that I have not messed up a re-line (YET!) considering how little I know about re-lining.

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Considering how much difficulty I had accumulating a hundred different trim charts and learning all the different methods used by different manufacturers (most of which are not written down), it amazes me how cavalier young jumpers are about re-lining canopies.



I was talking to one young rigger about line sets and he said the easy way to make a new line set was to carefully measure the old line set one line at a time. I realized that it was a waste of my time to argue with that type of "reasoning".:S[:/]

Sparky
My idea of a fair fight is clubbing baby seals

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Quote

Quote

Considering how much difficulty I had accumulating a hundred different trim charts and learning all the different methods used by different manufacturers (most of which are not written down), it amazes me how cavalier young jumpers are about re-lining canopies.



I was talking to one young rigger about line sets and he said the easy way to make a new line set was to carefully measure the old line set one line at a time. I realized that it was a waste of my time to argue with that type of "reasoning".:S[:/]

Sparky


_____________________________________

Ya' mean... that's not how you do it?:o[:/]:D


Chuck

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FARs are quite clear bout who can replace suspension lines: only Master Riggers.



after reading this i checked AC105-2C, the current version of part 105, and PPM volII. from what i have read, i feel a senior rigger could replace suspension lines on a non-certificated canopy all day long and be on pretty solid ground.

Quote

But skydivers can always find a way around any regulation ... even if it is only in their own mind!



i don't feel like i have found a loophole. if i am wrong about this i really want to know.

blue stuff,
p.j.


pulling is cool. keep it in the skin

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The text below is paragraph 12 from AC-105-2C.
Please read the part refering to line replacement.
It is considered a major repair.

Major repairs can not be done legally by Senior riggers unless supervised by a Master rigger.
Does not matter if it is a certified or non- certified(Main)

MEL


12 REPAIRS.
repairs.
Parachute repairs can be classed as major repairs or minor
A major repair, as defined in FAR Section 1.1, is a repair **...that,
if improperly done, might appreciably affect weight, balance, structural
strength, performance, powerplant operation, flight charactevistics, or other
qualities affecting airworthiness.” (Balance and powerplant operation do not
apply to parachutes.) A minor repair, as defined in FAR Section l.1,
8t . ..means a repair other than a major repair." Major repairs to parachutes
may be made by a master parachute rigger, an appropriately rated parachute
loft, or a manufacturer. Examples of major repairs are. replacement of a
canopy panel or suspension line, or sewing a large patch on a canopy. The
parachute manufacturer’s instructions should be followed when completing
repairs to any .portion of the parachute.
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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hey Mark,
i did read that paragraph, as well as the rest of AC-105-2C. according to PPM volII an advisory circular is not law, it is just meant to help inerpret the FARs. PPM volII also lists senior rigger as repair personnel for line replacement on non-certificated canopies. since i could manufacture bags of anvils and call them main parachutes and not violate the FAR's, i'm reasonably sure i wouldn't be taken to task for line replacement on said bag of anvils, even though i'm only a senior rigger.


pulling is cool. keep it in the skin

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Paul,
First off, AC's are used to further define the law and for guidance for rulemaking.

The PPM is not!

Senior riggers are the only ones that seem to think a senior rigger can replace lines!

Think about it!

Although there are several other areas that clearly define Major repairs, Modifications, and alterations to parachutes, most Senior riggers forget their previous training that explained that in detail.


An "emergency" AD is being brought up and written as I write this, to put a stop to that flawed thought process.

It should be out in Late Feburary!


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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hi Mark,
thank you for the input. i may not have been clear enough in my original post, but i was just trying to get another point of view on the topic. i was not trying to strike a nerve. i look forward to reading this AD you mention. it seems like that should take out alot of the grey areas that seem to exist.

blue stuff,
p.j.


pulling is cool. keep it in the skin

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