SSK 0 #26 August 16, 2006 Quote I can see where it is illegal to use the cypres once expired, but I do not see how it would be illegal to jump the rig. 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 Quote Share this post Link to post Share on other sites
riggerrob 643 #27 August 16, 2006 [I can see where it is illegal to use the cypress once expired, but I do not see how it would be illegal to jump the rig. >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> I forget exactly where in the FARs, but I know that it is illegal to carry a pilot emergency parachute - in the cockpit of an airplane - unless that PEP has been repacked within the last 120 days, in accordance with the manufacturers' instructions, etc. Since the regulations for PEPs and skydiving parachutes are identical, you could not legally carry a skydiving rig containing an expired Cypres in the passenger cabin of an FAA-registered airplane. Quote Share this post Link to post Share on other sites
rigger_john 0 #28 August 16, 2006 QuoteHere in Oz from what I understand you can shorten the repack cycle, by noting it on the card. So if you repack it, you can say that the next repack is due by the end September. Can you lot do that in the States or UK/Europe? We can in the UK, however we can only date the repack for the lifetime of the shortest lived component in the system, so in this case the customer would get a 1 month repack, and if he had the batteries replaced by the same rigger who did the original repack the expiry date could then be extended to the end of the AADS life._________________________________________ Nullius in Verba Quote Share this post Link to post Share on other sites
fcajump 164 #29 August 16, 2006 QuoteQuote I can see where it is illegal to use the cypres once expired, but I do not see how it would be illegal to jump the rig. 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 (Thanks Cliff) Maybe SSK could develope a removable "inop" sticker with date field that would go over the control unit sleave? JimAlways remember that some clouds are harder than others... Quote Share this post Link to post Share on other sites
masterrigger1 2 #30 August 16, 2006 Cliff, I guess we will have to agree to disagree on this subject. Quote 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 As you have already stated, the rules pertaining to parachutes and skydivers are somewhat "borrowed" from the aircraft rules. With that said, I have never seen a case where a aircraft had a shortened annual by simply noting something in the logbooks. Quote 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 If the prop has a AD or is "timed out" . It is illegal to fly. same goes for the ELT battery. It is spelled out in the FAR's. I follow the same principal in this case by not packing the reserve if the assembly will not make the full 120 days. Also, when you say "you" have no problem packing reserves..... What about the FAA having a problem? And not to step on your toes, but doesn't your responsibility stands solely with the AAD, not the Reserve? Another question, wasn't the original intent of the 3 month overrun period designed for maintaining a complete pack cycle? Cheers, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
mark 107 #31 August 16, 2006 QuoteIf the prop has a AD or is "timed out" . It is illegal to fly. same goes for the ELT battery. It is spelled out in the FAR's. Yes, but the FAR's actually support Cliff's point. If the prop has an upcoming AD "must do by" date or will time out soon, it is still legal to fly until the "must do by" date on the AD, or until it is timed out. The annual or 100-hour can be signed off even if that required maintenance is due before the next scheduled service. Same goes for the ELT battery, static system, and transponder. Mark Quote Share this post Link to post Share on other sites
mark 107 #32 August 16, 2006 QuoteUsing 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. The analogy does not apply. Aircraft may fly with some inoperative equipment, but until Airtec changes its instructions, an out of date Cypres may not be jumped. FAR 105.43(c) is explicit: "If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device." The FAR for tandem jumps adds that the AAD must be armed. Mark Quote Share this post Link to post Share on other sites
marinho 0 #33 August 16, 2006 Hi Cliff, What a wonderful discussion!!!!! That's why I posted this very important issue to our rigging comunity. Perra, I'm sorry, but the example I used wasn't your AAD. It happened, as Cliff remember, at the WFFC 2006! I have 2 points of view that I'd like to share with you guys: 1 - I believe that the rig, and its components, should be good for the period of 120 days as per manufacturer's and FAA rules. 2 - I also believe that if we could use option #2(from my original post), Airtec should states that on the cypres manual. So far I haven't had any problem by just telling the customer to have the unit replaced. It gives me and to the customer a good piece of mind! My concern is that no DZ on any country has a system that shows when your AAD expires. So it comes to my mind that the person will use the expired AAD, on or off anyway. Saying all that, my positioon is very clear. Educate the customer by telling him/her that there are only advantages on getting another AAD! The customer, Airtec/SSK and our company will benefit of having a perfect and on date AAD on the rig. Simple like that!!!!!!! Cheers,Gus Marinho Quote Share this post Link to post Share on other sites
masterrigger1 2 #34 August 16, 2006 Mark, I see Cliff's point also, but at the same time there are regulations that state exactly the fact that the airplane is not legal to fly. Therefore it is grounded! The airplane has 3 log books. One for each the prop, the engine, and the airframe. On the parachute there is only one log or record. BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
rigger_john 0 #35 August 16, 2006 Quote And this is the reason I would not pack it. I feel there are too many people who would ignore the fact that the AAD is out of date and jump the rig anyway. And with my seal on it. Why would that be your responsibility? wouldn't you just note on thr PDC that the rig expired when the life of the first componet expired. I know its just my opinion but it seems to me way to many riggers make the mistake of thinking we have to babysit our customers. I think they are big boys and girls and they can make thier own decisions. Any way I couldn't find any where in the FARs that said you had to sign a rig off for 120 days, only that is the maximum time between inspections. So when it leaves the loft it would be legal, as long as it was noted that it wasn't for 120 days what fars have been broken by the FAA rated members of our little sewing club? QuoteWhen it come right down to it, a rigger can refuse to pack a rig because he does not like the color. I know how you feel _________________________________________ Nullius in Verba Quote Share this post Link to post Share on other sites
rigger_john 0 #36 August 16, 2006 QuoteMy concern is that no DZ on any country has a system that shows when your AAD expires. So it comes to my mind that the person will use the expired AAD, on or off anyway. Wrong i'm afraid, here in the uk as well as the PDC each rig requires a current record of inspection. The PDC records when the reserve was packed and it's previous history. However the date of the next inspection or maintenance is recorded on the ROI. You have to have both bits of paper work to get your rig tagged as airworthy at a DZ. and the date of the next repack is 6 months from the repack or the date of expiry of the shortest lived sub component, AAD or power unit._________________________________________ Nullius in Verba Quote Share this post Link to post Share on other sites
fcajump 164 #37 August 16, 2006 Quote On the parachute there is only one log or record. BS, MEL This is one reason why some have been discussing multiple logs (though the discussion at the time was one for canopy and one for H/C.) So, should we be using 2 logs plus a third for AAD equipped rigs? For myself, I will keep to my own policy of not packing AAD's that will expire before the repack. JW JWAlways remember that some clouds are harder than others... Quote Share this post Link to post Share on other sites
riggerrob 643 #38 August 16, 2006 So, should we be using 2 logs plus a third for AAD equipped rigs? >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Nice in theory, but paperwork can quickly bog down a loft. For starters, most PDC pockets are barely big enough for one ... maybe two PDC. If you take this logic to its extreme, when I worked at Square One, riggers had to fill out SEVEN pieces of paperwork for every rig: packing data card, personal log book, loft log book, work order, pay sheet, etc. Sorry, but most riggers got into rigging because they hate paperwork. I could be earning far more money pushing papers around an office in Ottawa, but would have gone "postal" many years ago. Quote Share this post Link to post Share on other sites
dontiego 0 #39 August 16, 2006 In sweden, most cards have an expiration date for the rig. Like "good to jump until 31:st of september". If the card mentions the AAD's date of manufacture and last battery change, wouldn't it be solely the skydiver's responsability to have an airworthy equipment while jumping?"We call on the common man to rise up in revolt against this evil of typographical ignorance." http://bancomicsans.com Quote Share this post Link to post Share on other sites
fcajump 164 #40 August 16, 2006 QuoteIn sweden, most cards have an expiration date for the rig. Like "good to jump until 31:st of september". If the card mentions the AAD's date of manufacture and last battery change, wouldn't it be solely the skydiver's responsability to have an airworthy equipment while jumping? Ah... but the statement "good to jump until..." is something most riggers in the US would avoid with a passion... it would be used (by owners and their lawyers) to claim we are liable for a rig on the 119th day regardless of how it has been treated. Hence the reason we are pushing for wording that states (in essence...) "inspected on _____, and found airworthy at the time... NO guarentee of airworthyness after it leaves my custody." Now if you reworded it to "this gear not airworthy after _______", that might work...? JWAlways remember that some clouds are harder than others... Quote Share this post Link to post Share on other sites
masterrigger1 2 #41 August 16, 2006 Quote Any way I couldn't find any where in the FARs that said you had to sign a rig off for 120 days, only that is the maximum time between inspections. So when it leaves the loft it would be legal, as long as it was noted that it wasn't for 120 days what fars have been broken by the FAA rated members of our little sewing club? John, Did you happen to find anything in the FAR's that states you, the rigger, can in fact shorten a pack cycle? BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #42 August 16, 2006 Quote This is one reason why some have been discussing multiple logs (though the discussion at the time was one for canopy and one for H/C.) So, should we be using 2 logs plus a third for AAD equipped rigs? For myself, I will keep to my own policy of not packing AAD's that will expire before the repack. Jim, I think the Germans have it together in that sense. They require at least three, if not four logs. One for the H/C One for the reserve One for the AAD I think one for the main, but am not sure of it. As soon as someone( the right or wrong someone, whichever applies) in the FAA figures out that we are placing non-certifcated devices into TSO'd equipment, things will probably change. That change is going to cost us more money and headaches in the long run if it happens. The best thing to do IMHO is to kept the thing in date and service through out the pack cycle. The last thing anyone wants is to see 12 gray-haired ladies in a jury box. Imagine them at the moment a lawyer tells them you signed something off as being good when the manufacturer tells them the opposite. Food for thought, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
rigger_john 0 #43 August 16, 2006 QuoteDid you happen to find anything in the FAR's that states you, the rigger, can in fact shorten a pack cycle? No I didn't, but are you infering that the fars state both the maximum and the minimum requirments for the length of a repack. You seem to be implying if it's not in the fars in black and white then it can't be done. I wonder if that is really how you read the fars. Let me ask you a question then, when a overseas visitor turns up at your dz with his Javelin and tempo reserve and his 6 month repack done by a british advanced packer do you let him jump?_________________________________________ Nullius in Verba Quote Share this post Link to post Share on other sites
Derekbox 0 #44 August 16, 2006 If it is noted on the PDC that the cypress expires on such and such date, then that is legal notification for no matter who is using the rig, and if it isn’t your rig, ensuring it is in date is the user’s responsibility, which is done by checking the data card. As for the aircraft analogy, here is some clarification, unless it is a gross safety issue, aircraft are not grounded. If we note a squawk, (ELT battery expired for example), we will inform the customer that covers our responsibility. Further more, checking the ELT battery is not our responsibility unless we *have* to check it (under a phase inspection or annual for example). To make things even better, if the battery expires tomorrow, and we sign the aircraft off today, it was legal when it left. That covers our responsibility, it is up to the customer to maintain the airworthiness of the aircraft, we just do the work. Of course it is prudent of the customer to change the battery, but it is his responsibility to do so, not the mechanics. On the other side, if we noted it was expired, and did not tell him, we would have to bare the responsibility for that. So to parallel with rigging, if it leaves your hands legal and airworthy, maintaining the airworthiness status is the responsibility of the owner/operator. If I do an annual inspection, I don’t ground the airplane a year later when it doesn’t come back - not my responsibility. ;) Derek Quote Share this post Link to post Share on other sites
masterrigger1 2 #45 August 16, 2006 No I didn't, but are you infering that the fars state both the maximum and the minimum requirments for the length of a repack. You seem to be implying if it's not in the fars in black and white then it can't be done. I wonder if that is really how you read the fars. Quote I am simply stating that when you seal a parachute, you the rigger,are stating that the parachute and it's componets are airworthy for a 120 day pack cycle. With that, I do not know of any FAR or ruling that states or allows you to shorten a pack cycle. You seem to be implying if it's not in the fars in black and white then it can't be done. I wonder if that is really how you read the fars. Quote I am not saying it can't be done, just saying I do not think it's legal. Let me ask you a question then, when a overseas visitor turns up at your dz with his Javelin and tempo reserve and his 6 month repack done by a british advanced packer do you let him jump? *** It's repack Time! Unless the rig has the TSO label removed. Then the Non-TSO'd wavier will apply MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
SSK 0 #46 August 16, 2006 Hi Mel, Quote I guess we will have to agree to disagree on this subject. actually, I am not sure we are really in disagreement Quote I have never seen a case where a aircraft had a shortened annual by simply noting something in the logbooks. 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) QuoteIf the prop has a AD or is "timed out" . It is illegal to fly. same goes for the ELT battery. It is spelled out in the FAR's. agreed, already said our position is that the parachute should not be jumped after the AAD due date QuoteI follow the same principal in this case by not packing the reserve if the assembly will not make the full 120 days. agreed, already stated that I believe that this is an issue that is up to the individual rigger and what he feels comfortable with QuoteAlso, when you say "you" have no problem packing reserves..... What about the FAA having a problem? 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") QuoteAnd not to step on your toes, but doesn't your responsibility stands solely with the AAD, not the Reserve? 105.43(c) drags us into the matter QuoteAnother question, wasn't the original intent of the 3 month overrun period designed for maintaining a complete pack cycle? 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 Quote Share this post Link to post Share on other sites
rigger_john 0 #47 August 16, 2006 QuoteI am simply stating that when you seal a parachute, you the rigger,are stating that the parachute and it's componets are airworthy for a 120 day pack cycle. No, when I seal a parachute, or in my case sign off ( i tend not to seal, it not mandatory here) I am saying it was airworthy when I filled out the paper work. The second it's out of my door (rigging errors aside) it's the owners responsibility. As far as I can tell in the US it's also the owners responsibility and it appears the pilots too. (now there is a dumb rule)_________________________________________ Nullius in Verba Quote Share this post Link to post Share on other sites
masterrigger1 2 #48 August 16, 2006 Quote 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 Cliff, The one difference is the fact a pilot is certificated by the FAA to operate an airplane. If the pilot violates the law he can go to jail. If a jumper was found with it out of date and being used, the jumper would go scott-free and the rigger can now be held liable under the new rule. The point I am trying to make is this. The rigger certifies the rig and it's components are airworthy for 120 days by placing a seal on it. There is absolutely no FAA reg that says I or any other rigger can shorten the pack cycle. You pointed out 105.43. That cover the maintaince and service of the AAD, not the H/C or reserve parachute's pack cycle. Quote uote -------------------------------------------------------------------------------- Another question, wasn't the original intent of the 3 month overrun period designed for maintaining a complete pack cycle? -------------------------------------------------------------------------------- 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 Exactly my point. No matter if the pack cycle is 120 days, 6 months, or 1 year, the buffer would keep it in check. See you in Alexandria, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
masterrigger1 2 #49 August 16, 2006 John, Actually that's changed somewhat! From FAR 105: Parachute operation means the performance of all activity for the purpose of, or in support of, a parachute jump or a parachute drop. This parachute operation can involve, but is not limited to, the following persons: parachutist, parachutist in command and passenger in tandem parachute operations, drop zone or owner or operator, jump master, certificated parachute rigger, or pilot. BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
rigger_john 0 #50 August 16, 2006 so by your understanding of the fars if a jumper picks his rig up covers it in superglue, gets on an aircraft and jumps with it, the rigger is responsible because his seal says its good for 120 days after he sealed it! I find it hard to belive that you can take the fars to mean this. I stand by what I have said all the fars say is that a parachute must have been inspected, and packed by an appropriatley rated person within the last 120 days. There is nothing in there to imply (as far as i've seen) that the inspector has any responsibility for the airworthiness of a rig once it leaves his possesion. (again rigging errors aside) If I'm wrong then please show me where the fars say otherwise. Edit to add From FAR 105: Parachute operation means the performance of all activity for the purpose of, or in support of, a parachute jump or a parachute drop. This parachute operation can involve, but is not limited to, the following persons: parachutist, parachutist in command and passenger in tandem parachute operations, drop zone or owner or operator, jump master, certificated parachute rigger, or pilot_________________________________________ Nullius in Verba Quote Share this post Link to post Share on other sites
