QuoteIt's much easier to get a re-cert than to start from scratch. TSO approvial is expensive and time consuming. As for Mirage and the amount of work and testing that was done, well let's just say that's a topic for an unmoderated forum shall we?
Mick.
I wasn't saying that a change to the reserve pilot chute should require recertification on the current TSO, but a change to the shape of the main flaps, reserve flaps, pilot chute, reserve deployment system, blah blah blah.....all at the same time .... well anyway enough said
_________________________________________
Nullius in Verba
Nullius in Verba
QuoteQuoteIt's much easier to get a re-cert than to start from scratch. TSO approvial is expensive and time consuming. As for Mirage and the amount of work and testing that was done, well let's just say that's a topic for an unmoderated forum shall we?
Mick.
I wasn't saying that a change to the reserve pilot chute should require recertification on the current TSO, but a change to the shape of the main flaps, reserve flaps, pilot chute, reserve deployment system, blah blah blah.....all at the same time .... well anyway enough said
RE READ my post. THATS exactly what I'm talking about. Changing the whole thing under minor change rules.
Mick.
councilman24 37
And the CFR referenced in Sparky's attachment.
Lets see, going from a solid harness to an articulated harness seems to me would require heavy drops. Is that "substantially complete investigation"?
But add new reserve flap design, a free bag, new PC, one pin instead of two, etc. would seem to need function testing. Is that "substantially complete investigation"?
Hmm, maybe not enough change in the super swooper tandem (tandem meaning piggy back system) with a round reserve to the Racer to rise to the level of "substantially complete investigation".
Hmm, I can see where if the changes to get from Wonderhog to Vector III done incrimentally might never at one time rise to "substantially complete investigation" it seems like the total should.
But, going from a two pin old mirage to the new one pin mirage after 15 years or so to me seems to rise to needing "substantially complete investigation".
All three of these are TSO'd under C23b. I've never understood the ability to make these drastic design and function changes without re-certification.
Not to mention..... never mind, I won't mention it.
Quote§ 21.611 Design changes.
(a) Minor changes by the manufacturer
holding a TSO authorization. The manufacturer
of an article under an authorization
issued under this part may
make minor design changes (any
change other than a major change)
without further approval by the Administrator.
In this case, the changed
article keeps the original model number
(part numbers may be used to identify
minor changes) and the manufacturer
shall forward to the appropriate
Aircraft Certification Office for the geographic
area, any revised data that
are necessary for compliance with
§ 21.605(b).
(b) Major changes by manufacturer
holding a TSO authorization. Any design
change by the manufacturer that is extensive
enough to require a substantially
complete investigation to determine
compliance with a TSO is a major
change. Before making such a change,
the manufacturer shall assign a new
type or model designation to the article
and apply for an authorization
under § 21.605.
Lets see, going from a solid harness to an articulated harness seems to me would require heavy drops. Is that "substantially complete investigation"?
But add new reserve flap design, a free bag, new PC, one pin instead of two, etc. would seem to need function testing. Is that "substantially complete investigation"?
Hmm, maybe not enough change in the super swooper tandem (tandem meaning piggy back system) with a round reserve to the Racer to rise to the level of "substantially complete investigation".
Hmm, I can see where if the changes to get from Wonderhog to Vector III done incrimentally might never at one time rise to "substantially complete investigation" it seems like the total should.
But, going from a two pin old mirage to the new one pin mirage after 15 years or so to me seems to rise to needing "substantially complete investigation".
All three of these are TSO'd under C23b. I've never understood the ability to make these drastic design and function changes without re-certification.
Not to mention..... never mind, I won't mention it.
I'm old for my age.
Terry Urban
D-8631
FAA DPRE
Terry Urban
D-8631
FAA DPRE
reusch 0
Question:
Could it be that the Mirage, Mirage RTS, G3 and G4 from Mirage system has NO TSO?
I checked all 4 Manuals and at non of them the Word "TSO" is listed. Nor there is a FAA-TSO certification discription. Mirage system never ever said i that they have FAA-TSO for there H/C-Systems.
They said on page 4 (G3):
Low Speed
Parachute
Limited to use from
Airplane under 150 mph
what should means maybe C23d or c23b cat. c
and on the same page:
To lower the risk of death, serious bodily injury, canopy damage, container damage and
hard openings, never exceed 130 kts. deployment speed.
what should means maybe C23b cat. b
So what? Has anybody ever asked them what it means? And if they have TSO c23...whatever?
The Annex Inc. got for RTS1 and RTS2 TSO-c23b and Mirage takes over this to Models Rapid Transit System 1 & 2 - both 2-Pin H/C.
So what, if they never applied for 1-Pin TSO Certification? And a change from 2-pin in the back or horizontal 2-pin on top, to a 1-Pin on top is for sure not an minor-change!
And if it is an minor change in the opinion of FAA, please could somebody be so kind and switch the lights off at ACO, because it's a waste of time and money to asked this people for any certification!
Maybe somebody is able to figure that out?
Guido Reusch
Could it be that the Mirage, Mirage RTS, G3 and G4 from Mirage system has NO TSO?
I checked all 4 Manuals and at non of them the Word "TSO" is listed. Nor there is a FAA-TSO certification discription. Mirage system never ever said i that they have FAA-TSO for there H/C-Systems.
They said on page 4 (G3):
Low Speed
Parachute
Limited to use from
Airplane under 150 mph
what should means maybe C23d or c23b cat. c
and on the same page:
To lower the risk of death, serious bodily injury, canopy damage, container damage and
hard openings, never exceed 130 kts. deployment speed.
what should means maybe C23b cat. b
So what? Has anybody ever asked them what it means? And if they have TSO c23...whatever?
The Annex Inc. got for RTS1 and RTS2 TSO-c23b and Mirage takes over this to Models Rapid Transit System 1 & 2 - both 2-Pin H/C.
So what, if they never applied for 1-Pin TSO Certification? And a change from 2-pin in the back or horizontal 2-pin on top, to a 1-Pin on top is for sure not an minor-change!
And if it is an minor change in the opinion of FAA, please could somebody be so kind and switch the lights off at ACO, because it's a waste of time and money to asked this people for any certification!
Maybe somebody is able to figure that out?
Guido Reusch
QuoteQuestion:
Could it be that the Mirage, Mirage RTS, G3 and G4 from Mirage system has NO TSO?
I checked all 4 Manuals and at non of them the Word "TSO" is listed. Nor there is a FAA-TSO certification discription. Mirage system never ever said i that they have FAA-TSO for there H/C-Systems.
They said on page 4 (G3):
Low Speed
Parachute
Limited to use from
Airplane under 150 mph
what should means maybe C23d or c23b cat. c
and on the same page:
To lower the risk of death, serious bodily injury, canopy damage, container damage and
hard openings, never exceed 130 kts. deployment speed.
what should means maybe C23b cat. b
So what? Has anybody ever asked them what it means? And if they have TSO c23...whatever?
The Annex Inc. got for RTS1 and RTS2 TSO-c23b and Mirage takes over this to Models Rapid Transit System 1 & 2 - both 2-Pin H/C.
So what, if they never applied for 1-Pin TSO Certification? And a change from 2-pin in the back or horizontal 2-pin on top, to a 1-Pin on top is for sure not an minor-change!
And if it is an minor change in the opinion of FAA, please could somebody be so kind and switch the lights off at ACO, because it's a waste of time and money to asked this people for any certification!
Maybe somebody is able to figure that out?
And the penny drops!!!!
Mick.
councilman24 37
QuoteAnd a change from 2-pin in the back or horizontal 2-pin on top, to a 1-Pin on top is for sure not an minor-change!
If you ask Booth it is. Never asked anybody else.
Info from the FAA's web site:
QuoteTSO Number:
TSO-C23B TSO Title:
Personnel Parachutes Assemblies
Latest Update:
TSO Holder's Name:
Mirage Systems, Inc.
TSO Holder's Address:
1501A Lexington Avenue
DeLand FL 32721
United States
Responsible Office:
ACE-115A Atlanta Aircraft Certification Office Tel: (770) 703-6035
Part/Model Number & Name:
Rapid Transit(RTS-1) ===== Parachute Container System
Mirage (RTS-2) ===== Parachute Container System
For completeness RWS (they have a tso c23c for the tandems)
QuoteTSO Number:
TSO-C23B TSO Title:
Personnel Parachutes Assemblies
Latest Update:
TSO Holder's Name:
Relative Workshop
TSO Holder's Address:
1645 N. Lexington Avenue
DeLand FL 32724
United States
Responsible Office:
ACE-115A Atlanta Aircraft Certification Office Tel: (770) 703-6035
Part/Model Number & Name:
Wonderhog
and Jump Shack
QuoteTSO Number:
TSO-C23B TSO Title:
Personnel Parachutes Assemblies
Latest Update:
TSO Holder's Name:
Jump Shack, Inc.
TSO Holder's Address:
45620 - 12 Mile Road
Novi MI 48050
United States
Responsible Office:
ACE-115C Chicago Aircraft Certification Office Tel: (847) 294-7358
Part/Model Number & Name:
SST
from http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgtso.nsf/MainFrame?OpenFrameSet
I'm old for my age.
Terry Urban
D-8631
FAA DPRE
Terry Urban
D-8631
FAA DPRE
JerryBaumchen 1,354
Hi Terry (& to all of you posting on this one),
This post is in no way to insult anyone on their views, thoughts, etc about the TSO process. Iactually enjoy reading the input.
I am not an expert on the TSO process; but I have held numerous TSO's since '79.
I've always considered this TSO-thing kind of like pregnancy, one moment you are not a TSO holder & the next you are. There is no in-between or maybe about it.
Once you become a TSO holder you have entered into a different world, and a confusing one at times. I once had an FAA ACO employee tell me that anything that he would say to me was not binding, only that which they actually put into writing could they be held to. Almost like getting an answer from the IRS. Over the years I have found that is just how they work; in my experience, at least.
I have a document that was put out by the FAA many years ago called 'TECHNICAL STANDARD ORDER SYSTEM, Guide for Manufacturers.' I once gave a copy of it to Dan Poynter and he will sell you a copy. Terry, send me your address and I'll send you a copy.
In it it states under Design changes, Minor changes:
'A manufacturer possessing TSO authorization may make minor design changes to his article without applying for FAA approval.'
It goes on to state:
'The following items should be included in the manufacturer's notification of a minor change:
d. statement that the change will not affect the TSO compliance . . .'
IMO, what it comes down to is if the TSO holder states that his minor change (however extensive that change may be) still complies with the original TSO then that is it. My retired FAA-type/consultant that I use likes to tell me that the whole thing is based upon the honor system. That has been my experience, both as a TSO holder and as an observer of what other TSO holders have done/are doing.
As I've said before, a Vector III is only a
Wonderhog.
Now, I've probably added more confusion to this whole discussion with this, but such is life.
Jerry
PS) 'If it is not a major change then it is a minor change. If it is not a minor change then it is a major change.' Confusing? Yup.
This post is in no way to insult anyone on their views, thoughts, etc about the TSO process. Iactually enjoy reading the input.
I am not an expert on the TSO process; but I have held numerous TSO's since '79.
I've always considered this TSO-thing kind of like pregnancy, one moment you are not a TSO holder & the next you are. There is no in-between or maybe about it.
Once you become a TSO holder you have entered into a different world, and a confusing one at times. I once had an FAA ACO employee tell me that anything that he would say to me was not binding, only that which they actually put into writing could they be held to. Almost like getting an answer from the IRS. Over the years I have found that is just how they work; in my experience, at least.
I have a document that was put out by the FAA many years ago called 'TECHNICAL STANDARD ORDER SYSTEM, Guide for Manufacturers.' I once gave a copy of it to Dan Poynter and he will sell you a copy. Terry, send me your address and I'll send you a copy.
In it it states under Design changes, Minor changes:
'A manufacturer possessing TSO authorization may make minor design changes to his article without applying for FAA approval.'
It goes on to state:
'The following items should be included in the manufacturer's notification of a minor change:
d. statement that the change will not affect the TSO compliance . . .'
IMO, what it comes down to is if the TSO holder states that his minor change (however extensive that change may be) still complies with the original TSO then that is it. My retired FAA-type/consultant that I use likes to tell me that the whole thing is based upon the honor system. That has been my experience, both as a TSO holder and as an observer of what other TSO holders have done/are doing.
As I've said before, a Vector III is only a
Wonderhog.
Now, I've probably added more confusion to this whole discussion with this, but such is life.
Jerry
PS) 'If it is not a major change then it is a minor change. If it is not a minor change then it is a major change.' Confusing? Yup.
QuoteCould it be that the Mirage, Mirage RTS, G3 and G4 from Mirage system has NO TSO?
You are a rigger; you should know where to look on the rig to see if it has a TSO label/markings on it. Are you saying that the rig may not be TSO’d but is being manufactured with TSO markings?
It almost sounds like you have issues with US build gear.
Attached is a copy of Manufactures who hold a TSO.
My idea of a fair fight is clubbing baby seals
reusch 0
A name on a list, doesn't mean that the equipment I like to use is current or not! It only confirmed that the manufactory has a certification for what ever. With 30 Years in sport you should know that.
Mjosparky, please read by questions again (may it helps) and try to answer them, but please do not try to push me in a corner I'm not belong to! Thanks
To ask some critical questions doesn't mean to have issues to something or somebody! That should be possible, everytime, everywhere and for everybody (outside Guantanamo, ups.. sorry!)
Guido Reusch
Mjosparky, please read by questions again (may it helps) and try to answer them, but please do not try to push me in a corner I'm not belong to! Thanks
To ask some critical questions doesn't mean to have issues to something or somebody! That should be possible, everytime, everywhere and for everybody (outside Guantanamo, ups.. sorry!)
Guido Reusch
Quote(outside Guantanamo, ups.. sorry!)
This was in poor taste and uncalled for. You don't want to go there.
QuoteA name on a list, doesn't mean that the equipment I like to use is current or not! It only confirmed that the manufactory has a certification for what ever. With 30 Years in sport you should know that.
You are right their “name on a list” does not mean the equipment is currant under the TSO they hold but I would bet there is a very go chance it is.
QuoteMjosparky, please read by questions again (may it helps) and try to answer them, but please do not try to push me in a corner I'm not belong to! Thanks
I read your question and provided you with a place to find your own answer. Yes, Mirage holds a TSO on the gear the manufacture and sells.
As far as having issues, I have not heard you question the validity of the certification on gear manufactured in other countries.
My idea of a fair fight is clubbing baby seals
QuoteQuoteNow that Australia, Canada, New Zealand, South Africa, the European Union, etc. have adopted FAA TSO standards,
I would say that the USA has adopded the European standards as 8015b is the standard for the 23d.
I think the point reusch was trying to make, is that most US manufactures ignore the TSO and put thier new equipment through as minor changes to designs approved under TSO 23c.
hence his list
Javelin Odyssee
Vector III Micron
Mirage G4
and Power Racer ??????????
Exactly what non-minor changes have been made to the Racer?
For Great Deals on Gear
QuoteAs for Mirage and the amount of work and testing that was done, well let's just say that's a topic for an unmoderated forum shall we?
I don't think I've ever heard that not said so diplomatically.
For Great Deals on Gear
councilman24 37
QuoteExactly what non-minor changes have been made to the Racer?
Well, since it seems that minor and major changes are defined by the manufacturer, I guess none.
But I would wonder about articulated harnesses. Changes in harness configuration, construction and the addition of a new type of load bearing component (ring) might be considered a major change by some. And from a SST designed for rounds to the addition of freebags for squares seems like a significant change to me.
But, I don't understand any of these minor changes by any manufacturer.
I'm old for my age.
Terry Urban
D-8631
FAA DPRE
Terry Urban
D-8631
FAA DPRE
JerryBaumchen 1,354
Terry,
When we get to Reno next January, find me, buy me a drink and I guarantee you that when we are finished discussing 'minor changes,' you will know it as good as I do.
Jerry
When we get to Reno next January, find me, buy me a drink and I guarantee you that when we are finished discussing 'minor changes,' you will know it as good as I do.
Jerry
QuoteTerry,
When we get to Reno next January, find me, buy me a drink and I guarantee you that when we are finished discussing 'minor changes,' you will know it as good as I do.
Jerry
Hell give a date snd I'll update both of you on how this shit works, minor change my ass.
Mick.
Quote
Javelin Odyssee
Vector III Micron
Mirage G4
and Power Racer ?????????
Exactly what non-minor changes have been made to the Racer?
Well It wasn't my list but I think, Terry Urban has replied as well as I could.
_________________________________________
Nullius in Verba
Nullius in Verba
reusch 0
That sound fair!! You guys will meet at Reno, and having beer, and we are sitting here without an answer!
So, please let us also take part of the mystical X-File "MINOR CHANGES"!
Guido Reusch
So, please let us also take part of the mystical X-File "MINOR CHANGES"!
Guido Reusch
Pablito 0
just ask your local rigger he/she should know the rules.
"If you don't overcome your fears they will overcome you first"
Shady Monkey/6Segundos Rodriguez/AKA Pablito
"If you don't overcome your fears they will overcome you first"
Shady Monkey/6Segundos Rodriguez/AKA Pablito
Quotejust ask your local rigger he/she should know the rules.
I would venture a guess that not 1 in 10 riggers understand the TSO process, what’s involved in getting one or what needs to be done to maintain compliance with a TSO once it is issued. This is not a slam against riggers, it just that there are not many opportunities to be involved in the applying for one.
My idea of a fair fight is clubbing baby seals
If you are saying that when the mirage became th G4, ect that the manufactures extensivly tested all the changes, then why not just apply for 23d?
It's much easier to get a re-cert than to start from scratch. TSO approvial is expensive and time consuming. As for Mirage and the amount of work and testing that was done, well let's just say that's a topic for an unmoderated forum shall we?
Mick.