FAA: Altering Main Canopies

[TowerTopper 0]

That's what I'm thinking Mark and the Raven "Reserve" in my flag rig just shows a good loop hole in some of the reqs out there. By the way I do work under the supervision of other licensed riggers and not just winging it.

I would be interested taking a riggers course ASAP if anyone knows of one sooner than May, I've been rigging a few years and it's time. I could do it without the course but I would have to find somewhere outside of Indiana anyway to test and it never hurts to see what other people are doing also. I'm wanting all 3 ratings: Seat, Back, and Chest. E-mail me here.

[councilman24 37]

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How about this, I have a Raven main/reserve I mentioned in another post, using it as a reserve now after first 300+ jumps skydiving it and had a save on it as a reserve after that. My point is I altered/patched it twice as my main and I'm not a licensed rigger. Now it's a reserve, patched, no history other than I know I patched it when it was a main and no other rigger would know that, they would just inspect it and start a new card.

No other rigger SHOULD start a new card and call it good. And what you've done is illegal. From the manual:

"A canopy which has been intentionally
jumped as a main canopy (beyond
one familiarization jump prior to
reserve packing )should not be packed
or used as a reserve- You
may, however, use a canopy which
has been previously packed as a
reserve as a main canopy. After you
jump the canopy as a
main, do not return it to Service as a
reserve."

"

A Raven, once used as a main, is no longer certified for use as a reserve. And it is just not a good idea to use a canopy with 300 jumps as a reserve. As a benchmark remember that PD only allows 25 RESERVE deployments before being reevaluating by the factor. Any rigger should be able to tell it was a main and NOT pack it as a reserve.

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

[councilman24 37]

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I'd like to use your example to make this point: a senior rigger with the plastic barely cooled on his card (updated idiom from "ink still wet on his certificate") is charged with the responsibility every pack cycle of inspecting reserve canopies with someone else's major repairs, and approving for them return to service. Now, if he can inspect someone else's work and approve it, why shouldn't he be allowed to inspect his own?

Mark

There are LOTS of things that I can inspect and judge the quaility of or the adherance to standards that I can't DO myself. Cutting hand dove tails, Figure Skating, cutting a room paint edge, and lots of other things. I can't finish drywall worth a damn. But I can tell when someone has done a good job or a bad job. I don't think your inspection cabability equals execution ability is valid. And inspecting your own work to determine ability strikes me as an extreme confict of interest Hence the practical exam.

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

[mark 107]

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There are LOTS of things that I can inspect and judge the quality of or the adherence to standards that I can't DO myself. Cutting hand dove tails, Figure Skating, cutting a room paint edge, and lots of other things. I can't finish drywall worth a damn. But I can tell when someone has done a good job or a bad job. I don't think your inspection capability equals execution ability is valid. And inspecting your own work to determine ability strikes me as an extreme conflict of interest. Hence the practical exam.

I agree that ability to inspect is not the same as ability to execute. I don't think I made the claim they were equal.

I can't finish drywall with a damn, either, but that was a result of trying it and evaluating my own work. I didn't need anybody else to tell me how well I did, and while I was chagrined by Lynne's critique, I wasn't surprised.

But I agree that a second set of eyes is almost always better, even when you're working within the legal limits of your certificate.

Cheers,
Mark

[rushmc 23]

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I have in the past sewn on tail pockets to different skydiving canopies, some down and dirty right threw the tail of the canopy with no backing and base jumped those and then jumped them from the aircraft also after using them of BASE, where the canopies are now? Who knows, I sold them over the years and I'm sure at some point in time they were skydived again not by me, altered by me not jumped by me no more.

How about this, I have a Raven main/reserve I mentioned in another post, using it as a reserve now after first 300+ jumps skydiving it and had a save on it as a reserve after that. My point is I altered/patched it twice as my main and I'm not a licensed rigger. Now it's a reserve, patched, no history other than I know I patched it when it was a main and no other rigger would know that, they would just inspect it and start a new card.

I have no doubt that what you say here was done. I would never do it. I will not even touch lines on a reserve. That, to me, if for those rated, qualified and confident (with factory blessing) to do work on reserves.

However, this thread, being about working on mains is much different.

There are those saying only a master rigger should change lines on a main. And some are actively working to convince the FAA that this is what the intent was but the rules were poorly written. While not as informed as many here I do not agree.

And even if inteneded, how would or could it be enforced when no documentation is or will not be required? It makes little sense to me.

So, why respond to you? You post an example of the extreems that can and do happen. With reserves no less, why would some riggers and the FAA want to try and deal with mains when things such as you post happen with reserves???

I am still learning but some of what I have read in this thread does not pass the stink test with me. But, it could be my nose to.

"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

[riggerrob 643]

I would invite you to riggers courses - that I am teaching this winter - except that you are already so far outside the law, that you scare me!

After the way you beaked-off - in earlier postings - about openly defying the law, the I would never recommend you for a rigger's rating.

Rob Warner
FAA Master Rigger
CSPA Rigger Instructor
German Prufur Classe A

[councilman24 37]

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There are those saying only a master rigger should change lines on a main. And some are actively working to convince the FAA that this is what the intent was but the rules were poorly written. While not as informed as many here I do not agree.

And even if inteneded, how would or could it be enforced when no documentation is or will not be required? It makes little sense to me.

No one is actively working to convince the FAA that only a master should change main lines (one example). That was always the FAA's position until they screwed up a rewrite. They have found and admited the rewrite error to me after I pointed it out. Others had pointed it out but had never quite sunk home.

After phone discussions with the FAA in early 2007 and them agreeing that they screwed up I received this in an email from them on April 6th 2007.

"The final rule language to correct 65.111 is being reviewed by legal. Do not have a release day as yet, but will let you know when I get it."

Once more the time line.

FOREVER, only a master rigger could do a major repair to and alter a main. And remember, any alteration must have the approval of the manufacturer or a field approval from the FAA. A master rigger can't alter either a main or reserve without the paper work.

Mains in the FAA regs are treated JUST LIKE reserves EXCEPT no certification and no documentation and can be PACKED by the next person going to jump them.

In 2001 when the FAA rewrote part 65 to make tandem legal they screwed up. That is not my or any other riggers opinion, it is the FAA's opinion. I pointed it out to them. Two days later, after reviewing the NPRM for 2001, the old language, and the new language they realized THEY made a mistake. We all agree with what it says in writing now but that is NOT what the FAA intended and they are working to fix there mistake.

Whether you believe it SHOULD be that way or not it, has been since the rules were written in the mid 1900's. I WAS taught that anyone could do anything to a main. THAT was never true.

NO it can't be inforced unless someone gets hurt, there is an investigation, and the violation is proved. If you expect the FAR's to make sense you in fantasy land.

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

[rushmc 23]

From what I have seen in this very thread you cant back this up, you only have an opinion on it.

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FOREVER, only a master rigger could do a major repair to and alter a main. And remember, any alteration must have the approval of the manufacturer or a field approval from the FAA. A master rigger can't alter either a main or reserve without the paper work.

Hell, even Poyntes does not agree with you. History doesnt agree with you.




And your post was very polite untill your comment followed by the winkey eye you used trying to soften it

"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

[riggerpaul 1]

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From what I have seen in this very thread you cant back this up, you only have an opinion on it.

Quote

FOREVER, only a master rigger could do a major repair to and alter a main. And remember, any alteration must have the approval of the manufacturer or a field approval from the FAA. A master rigger can't alter either a main or reserve without the paper work.

Hell, even Poyntes does not agree with you. History doesnt agree with you.

Though I am not at all pleased by it, and Poynter notwithstanding, my research has shown me that councilman24 is correct. That is, FAR 65.111 has always contained language that called for an FAA Rigging Certificate to work on mains.

I have old manuals that contain the pre-2001 text of 65.111, and they are clear that this requirement has been around for a long time. This isn't new. It didn't happen in the 2001 rewrite.

And, just as councilman24 mentions regarding his training, my training also included people telling me that anyone can work on mains.

So, while Poynter may disagree, I have to say that *history* does support Terry's (councilman24) statement. And, just to be clear, Poynter was NEVER law, while 65.111 has always been.

[rushmc 23]

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From what I have seen in this very thread you cant back this up, you only have an opinion on it.

Quote

FOREVER, only a master rigger could do a major repair to and alter a main. And remember, any alteration must have the approval of the manufacturer or a field approval from the FAA. A master rigger can't alter either a main or reserve without the paper work.

Hell, even Poyntes does not agree with you. History doesnt agree with you.

Though I am not at all pleased by it, and Poynter notwithstanding, my research has shown me that councilman24 is correct. That is, FAR 65.111 has always contained language that called for an FAA Rigging Certificate to work on mains.

I have old manuals that contain the pre-2001 text of 65.111, and they are clear that this requirement has been around for a long time. This isn't new. It didn't happen in the 2001 rewrite.

And, just as councilman24 mentions regarding his training, my training also included people telling me that anyone can work on mains.

So, while Poynter may disagree, I have to say that *history* does support Terry's (councilman24) statement. And, just to be clear, Poynter was NEVER law, while 65.111 has always been.

Fair enough but it sure seems counter intuitive to me

"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

[riggerrob 643]

"Counter intuitive?"
Hah!
You should try reading the Canadian Air Regulations!
They are all written in double-negatives!

[riggerrob 643]

I am backing councilman in this debate.

I have been jumping even longer than him - since the 1970s.
When I earned my FAA rigger rating in 1988, I learned everything I need to know about FARs.

Please do not clutter my mind with new interpretations.
Tee!
Hee!

[rushmc 23]

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"Counter intuitive?"
Hah!
You should try reading the Canadian Air Regulations!
They are all written in double-negatives!

The fun of legal speak

"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

[councilman24 37]

The wink referred to the FAA making sense only.

I've went back and read the ORIGINAL FAR's and ever revision and the justifying documents since they were adopted in 30's (may have been the 40's) I was looking for when it changed. It was always as I stated. BUT, even many manufacturers that are old timers believe(d) mains were unregulated. I asked at a PIA meeting. Showed them the regs and they agreed they were wrong. We were all taught that anybody could do anything to a main. And we were all taught wrong!

The way the discussion went.

Me "Who believes that mains are unregulated."

Half the room raised their hands. This was the PIA rigging committee meeting immediately prior to a symposium. And included principles in several major companies. Name are ommited to prevent embarassment.

Me "What about the 120 day inspection and repack? Mains have that right? Just no documentation"

All agreed because we were all taught that nuance in the regs.

Me "But what about major repairs and alterations?"

Some said anybody.

Me "But don't you still need approval for an alteration?"

Most agreed.

Me "And who can pack a main?"

Everybody agreed a rigger or the next jumper.

Me "Isn't that regulation?"

Well yes.

Me "And here is the regs from before 2001 that dictates applies everything to mains except paper work and the packing exception."

Most of the group. "Hmmm, your right"



I'm not advocating one position or another here. I'm just relaying the way it is. The ONLY reason it's been different since 2001 is the FAA can't write and understand english. They never intended to change this as demonstrated by all of the discussion that accompanies a NPRM. After reviewing the previous language, the new language and the justifying documents the FAA staff and lawyers agreed they'd done something they didn't intend and were going to 'fix' their error.

And Poynter's does agree with me because he reproduces the regulation. And in the 1977 printing also quotes the General AViation Operations Inspectors Handbook (84r40.5A)

"4065. ALTERATION OF THE MAIN PARACHUTE. The main parachute of a dual parachute pack to be used for intentional jumping may be altered bya master parachute rigger, a parachute loft, the manufacturer or any other manufacturer the Administrator considers to be competent. ...." Goes on to exempt these alterations from facilities requirments, recording and sealing.

My latest Poynters is pre 2001. I don't know if he revised it to reflect the miswritten regulations or not.

And to the position that anybody SHOULD be able to do anything to a main. Should that include student canopies, rental gear, and tandem mains with unsuspecting users?

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

[rushmc 23]

Ok, thanks

Sorry for my misunderstanding your post and thank you for taking the time to post this.

It is frustrating to find out what one was taught is, well, incorrect.

I guess I will suck it up. Do 100 pack jobs (of a different type) for no good reason other than getting the numbers and get my Master ticket.

Thanks again

Marc

"America will never be destroyed from the outside,
if we falter and lose our freedoms,
it will be because we destroyed ourselves."
Abraham Lincoln

[rushmc 23]

And to the position that anybody SHOULD be able to do anything to a main. Should that include student canopies, rental gear, and tandem mains with unsuspecting users?

[ChangoLanzao 0]

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I'm not advocating one position or another here. I'm just relaying the way it is. The ONLY reason it's been different since 2001 is the FAA can't write and understand english. They never intended to change this as demonstrated by all of the discussion that accompanies a NPRM. After reviewing the previous language, the new language and the justifying documents the FAA staff and lawyers agreed they'd done something they didn't intend and were going to 'fix' their error.

So are you saying that you believe the FAA used to write and understand english when the original regs were written? If so, what makes you think so?

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And Poynter's does agree with me because he reproduces the regulation. And in the 1977 printing also quotes the General AViation Operations Inspectors Handbook (84r40.5A)

"4065. ALTERATION OF THE MAIN PARACHUTE. The main parachute of a dual parachute pack to be used for intentional jumping may be altered bya master parachute rigger, a parachute loft, the manufacturer or any other manufacturer the Administrator considers to be competent. ...." Goes on to exempt these alterations from facilities requirments, recording and sealing.

I'm just a newbie, but it sure seems to me that if you presuppose that the above is the correct version, to be taken literally, it is giving explicit permission to Master riggers to do all that stuff to mains. It doesn't explicitly prohibit anyone else from working on them. If that was the FAA's intention, all they had to do was ad the word ONLY in the right places.

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My latest Poynters is pre 2001. I don't know if he revised it to reflect the miswritten regulations or not.

Perhaps he and many others back then thought the regs were not written properly, and just chose to ignore this rather than getting the FAA all worked up into a rewriting frenzy? I don't know, I'm just saying.

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And to the position that anybody SHOULD be able to do anything to a main. Should that include student canopies, rental gear, and tandem mains with unsuspecting users?

Yup. I would think so. God only knows what the result would be if the FAA starting writing more regulation on this topic, considering the mess we seem to already be in trying to figure out what the the current regs mean.

[fcajump 164]

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Question... In conversation with some other riggers/skydivers the following came up...

This question is for riggers and/or people that know the regulations and can cite their source.

FYI - found this on the FAA's site in a document uses as guidance to the FAA inspectors:

8-476 ALTERATION OF THE MAIN PARACHUTE.
A. The main parachute of a dual parachute pack to be used for intentional jumping may be altered by a master parachute rigger, the manufacturer, or any other manufacturer the Administrator considers to be competent. The alterations are not required to be made in accordance with approved manuals and specifications (14 CFR § 65.125(c)). Master parachute riggers are not required to comply with 14 CFR sections (§§) 65.127 through 65.133 (relating to facilities, equipment, performance standards, records, recent experience, and seal) when altering the main parachute.
B. Any change to the configuration, method of operation, or method of packing the main parachute, up to and including the main canopy attachment links or the male end of the quick release fittings, is a main pack alteration. Any main parachute alteration that affects the strength or operation of the auxiliary parachute, including the harness, must be regarded as an alteration of the auxiliary parachute and handled accordingly.

http://fsims.faa.gov/PICResults.aspx?mode=Search&q=parachute&kw=parachute&status=a&syn=1&sort=0&
--------------

Not saying I think their position is right/wrong or even clear when it comes to certain detials... just this is what they tell their own people...

Take it for what its worth.

JW

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

[tdog 0]

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male end of the quick release fittings

Wow, I did not know my rig had a quick release penis???

[mark 107]

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male end of the quick release fittings

Wow, I did not know my rig had a quick release penis???

Capewell release. I'm sorry I remember when they were common on sport rigs.

Mark

[tdog 0]

I know..... Just making a funny.