180 Day Repack news

[diablopilot 2]

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65.111 has already been re-written to reflect it's original intent and will come out at the same time as the 180 day repack cycle.

And what shall that be?

Is this where we find out that we've been bad children for maintaining our own main parachutes?

----------------------------------------------
You're not as good as you think you are. Seriously.

[pchapman 279]

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As I read the change, tandems will also go to 180 days.

105.45(b)(2) establishes tandem reserve pack requirements "in accordance with Sec. 105.43(b) of this part." 105.43(b) is what was changed, so tandem reserve pack requirements (pack cycle, who can pack) change in synch by reference.

Interesting, Mark!
Like you originally, I missed that reference in the 105.45 tandem section.

But the FAA really tries to confuse us.

In the doc Howard provided, the FAA specifically stated that the rule changes have nothing to do with tandems:

"Another commenter stated that this
rule should also apply to the main
parachute of a dual harness/dual
parachute (tandem) system and that
‘‘the 180 day requirement should be
applied to such systems to give at least
the same level of control as single
harness/dual parachute systems.’’
Although this comment may have some
merit, it too is beyond the narrow scope
of this rulemaking, which addresses
only single harness, dual parachute
systems. The FAA will consider this
issue for possible inclusion into future
rulemaking."

[rehmwa 2]

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Earlier suggestions in dz.com threads were made that previous pack jobs would be only good for 120, yet I don't see language that prevents old pack jobs from automatically becoming good for 180.

I'll just wait to repack until after 19 Dec to avoid the inevitable pissing and moaning from different pilots, riggers, and DZOs that each interpret this change the way they want to.

edit: Actually, it might be fun to show up at the local DZs during the two weeks I'd have extension potential to just to see what their stances are (I'm out of date from early Nov based on 120 days, until Dec 19, then potentially in date for a couple weeks based on 180 days)

In any case, a couple months past Dec 19, then this little bit becomes a moot point.

...
Driving is a one dimensional activity - a monkey can do it - being proud of your driving abilities is like being proud of being able to put on pants

[Communications 0]

Hi guys, just a quick update - Ed Scott, USPA's Executive Director, Randy Ottinger, Director of Government Relations, and Cliff Schmucker, PIA President, are headed to FAA offices as we speak to meet with officials on this ruling. We're posting updates to the USPA news page and blog as we get them and will try to get all questions answered!

~Lara
lkjeldsen@uspa.org

www.uspa.org

Read the USPA blog!

[ozzy13 0]

§ 105.43 Use of single-harness, dual parachute
systems.
* * * * *
(a) The main parachute must have
been packed within 180 days before the
date of its use by a certificated
parachute rigger, the person making the
next jump with that parachute, or a non certificated
person under the direct
supervision of a certificated parachute
rigger.


I got this from the link below page 6 left column
http://edocket.access.gpo.gov/2008/pdf/E8-27459.pdf

So the rule for packers have not change if I am reading this correct. Just the the amount of days that it has to be done in.
You don't need to be a rigger to pack mains for other people , Correct?

Another question I have . I have given packing classes to students. Is that allowed?( For Mains) I always thought it was and now I am wondering if it is.

Never give the gates up and always trust your rears!

[masterrigger1 2]

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I'll just wait to repack until after 19 Dec to avoid the inevitable pissing and moaning from different pilots, riggers, and DZOs that each interpret this change the way they want to.

edit: Actually, it might be fun to show up at the local DZs during the two weeks I'd have extension potential to just to see what their stances are (I'm out of date from early Nov based on 120 days, until Dec 19, then potentially in date for a couple weeks based on 180 days)

In any case, a couple months past Dec 19, then this little bit becomes a moot point.

News update!

I received this email this AM from AFS-350 (washington). The FAA stance is totally different from what I was previously informed it to be, but seems to be for the better.

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Mark,

The way the rule is written the 180 days starts with the date of the last
repack.

Example, if you have a parachute that hits the current 120 days on December
15 you can not jump the parachute on the 16th, 17th and 18th, but can go
back to jumping the parachute on the 19th when the new rule goes into
effect until is reaches 180 days.

So there you have it!

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[ozzy13 0]

That great!!! I just had both my rigs repacked in the past month.

Never give the gates up and always trust your rears!

[ficus 0]

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To my opinion the Senior Rigger supervising others for the 20 reserve repacks should be changed.

It is not logic that a person that got his senior rigger ticket 24 hours ago or so can supervise or train a person packing 20 reserves for the FAA test for the same rating/s he/she holds.

I see where you're coming from here. It does seem strange that a new rigger could sign off pack jobs while the ink is still drying on his ticket.

But if this new rigger is equipped to know the correctness of his own work (and he is, according to his brand new ticket), then he is equipped to verify the correctness of another's work.

A Master Rigger does not even necessarily have more experience than a Senior Rigger. The Master Rigger has demonstrated a higher breadth and depth of rigging competence, but competence in rigging does not necessarily equate to competence in teaching. If anything, you ought to be arguing for a Rigger Instructor rating. (More regulation from the FAA, just what we need :)

Besides, at the end of the day, the rigger(s) supervising those first 20 packjobs don't hand out the ticket -- the candidate still needs to pass muster with the DPRE.

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Being a rigger is much more then 20 repacks under supervision.

Of course, and this is why the DPRE tests on much more than just a reserve I&R.

Ficus

[peregrinerose 0]

Isn't that going to cause an issue with cypres maintanance dates? Say a Cypres is supposed to go out in December. But the jumper keeps jumping it for the additional 60 days due to the rule change... say the jumper goes in, so this is investigated.... is the rigger who packed it under the 120 day rules responsible for the cypres being jumped outside manufacturers recommendations? Is the jumper responsible for ensuring this isn't a problem? The DZ? Does this question even make sense??
I'm not sure that grandfathering all repacks is a good idea, just based on that.

Do or do not, there is no try -Yoda

[Squeak 17]

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Isn't that going to cause an issue with cypres maintanance dates? Say a Cypres is supposed to go out in December..

There is a grace period before and after the due date, to allow for such things
The US is now going to 180 day cycles MANY parts of the rest of the skydiving world are and have been on 180 for a long time

You are not now, nor will you ever be, good enough to not die in this sport (Sparky)
My Life ROCKS!
How's yours doing?

[sunshine 2]

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Isn't that going to cause an issue with cypres maintanance dates? Say a Cypres is supposed to go out in December..
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There is a grace period before and after the due date, to allow for such things

The +/- 3 months does not apply to the 2yr battery replacement.

___________________________________________
meow

I get a Mike hug! I get a Mike hug!

[tdog 0]

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Isn't that going to cause an issue with cypres maintanance dates? Say a Cypres is supposed to go out in December..
-------------------------------------------------
There is a grace period before and after the due date, to allow for such things

The +/- 3 months does not apply to the 2yr battery replacement.

I think Cypres 1 owners need to consider when their battery will be due next, as it is a common practice for a rigger to refuse to pack a rig where the battery will expire in the packjob... Hence, if you are 5 months away from a battery expiration, previously that rigger would have packed your rig - now the rigger will replace the battery too...

[johnny1488 1]

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I think Cypres 1 owners need to consider when their battery will be due next,

That's funny.

"But I just did the batteries"

I do see a problem with the grandfathering. I will pack a rig if the 120 days of the repack dont go past the battery due date, now one of my pack jobs could be legally in date with out of date batteries, and it's my seal on it, not the jumpers.

Im not really concerned, cause I havent done any batteries lately, just hypotheticly.

Johnny
--"This ain't no book club, we're all gonna die!"
Mike Rome

[dpreguy 14]

I don't think anyone could claim to be surprised by this rule change. It is a new rule. Live with it. It doesn't make any difference whether one "supports" it or not. Game over. I didn't see the implementation date of Dec 19th, but will take that as correct. (Yes I read the part that it becomes effective 30 days after the ...notice date).

This is all pretty simple: Until Dec 19th, the existing rule is in effect. After Dec 19th, the new rule is in effect, and since it states,"...approved parachute...blah blah..must have been packed within 180 days of use...blah blah...", then that's what it means. Yes, unless there is some quick interim advisory, it means that it is "retroactive." So what? What's the problem? I don't see any legal or practical problem, except the Cpres battery in Cypres 1's will be timed out in many instances. (Or in rare instances , a Cypres 1 unit could time out)

Opinion: I predict CypresGimbl/SSK will readily accommodate this transition period, with certain logical instructions or cautions. I have no information or authority to say that they will, it's just my guess, as these folks are extremely astute, and were not surprised at all by this rule change. I'll call Eric C. tomorrow and see if the company has taken a position on batteries or units that time out in Cypres 1's becuase of this rule change. If they have, (or haven't) I'll post. Since Cypres 2's have a + 6 month window, they aren't affected in any way.

[Gary73 10]

dpreguy,

Please fill in your profile. Thanks.

"Extraordinary claims require extraordinary evidence." - Carl Sagan

[Gary73 10]

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Isn't that going to cause an issue with cypres maintanance dates? Say a Cypres is supposed to go out in December. But the jumper keeps jumping it for the additional 60 days due to the rule change... say the jumper goes in, so this is investigated.... is the rigger who packed it under the 120 day rules responsible for the cypres being jumped outside manufacturers recommendations? Is the jumper responsible for ensuring this isn't a problem? The DZ? Does this question even make sense??
I'm not sure that grandfathering all repacks is a good idea, just based on that.

Jen,

As I understand it, nothing has really changed. There has always been the possibility that a legally packed reserve and CYPRES will have its battery hit the 2-year mark or its AAD need its service before the next repack. The FAA only says that "If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device." Airtec requires that "the batteries be replaced the first time the low battery error code (8998/8999) is encountered during self-test, or every two years, or every 500 jumps, which ever of these occurs first." They only recommend that the owner have the rigger "replace the battery if the two year period will be up before the next scheduled repack". In other words, the rigger is no more responsible for making sure that the two-year point isn't hit during the upcoming cycle than he is for making sure that the 500-jump point isn't hit. Or the 8998-code point, for that matter.

Now if the owner intends to be jumping throughout the 180-day cycle, it's certainly a good idea to go ahead and have the rigger replace the battery and/or send the unit in for maintenance if it's going to need it during the repack cycle, but that's the owner's choice. For all the rigger knows, the owner isn't going to be jumping during that post-two-year-pre-180-day period. The rigger should make sure that the owner understands the options before doing the pack job, but has met his legal obligations as long as the rig is legal the day it's signed and sealed. The owner is responsible after that, just as he is responsible for making sure that the seal is intact and that the rig passes an external inspection before every jump.

Jumpers and riggers in a lot of other countries have been facing this issue for years now, seeing as most other countries have had repack cycles longer than 120 days for a long time now. We just need to educate our customers regarding the consequences of the new cycle, especially during the transition period.

"Extraordinary claims require extraordinary evidence." - Carl Sagan

[peregrinerose 0]

I think you are missing what I was asking....

Let's say I did a repack (this is a hypothetical scenario, not one I'm actually in)- Under the 120 day rule, the repack would expire Dec 20th.

On this particular rig, the cypres1 goes out of date (12 years plus 3 months, so DOM September 1996) December 2008.

Since the repack now gets an extra 60 days, the repack date moves to Feb 2009. However, the cypres 1 is out December 2008.

That means that the cypres is being used outside the manufacturers requirements with my seal on the container.

Had I known that the effective date for the 180 days was Dec 19 prior to doing the repack, I would not have repacked the reserve with that cypres, knowing that it would have to go out of service during the 180 day cycle However, since it would have been ok for the 120 day cycle, it was packed.

Does the question make more sense now? It's not a situation I am actually facing... it was just easier to rephrase the question that way (already checked to make sure of that

Do or do not, there is no try -Yoda

[Andrewwhyte 1]

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I think you are missing what I was asking....

Let's say I did a repack (this is a hypothetical scenario, not one I'm actually in)- Under the 120 day rule, the repack would expire Dec 20th.

On this particular rig, the cypres1 goes out of date (12 years plus 3 months, so DOM September 1996) December 2008.

Since the repack now gets an extra 60 days, the repack date moves to Feb 2009. However, the cypres 1 is out December 2008.

That means that the cypres is being used outside the manufacturers requirements with my seal on the container.

Had I known that the effective date for the 180 days was Dec 19 prior to doing the repack, I would not have repacked the reserve with that cypres, knowing that it would have to go out of service during the 180 day cycle However, since it would have been ok for the 120 day cycle, it was packed.

Does the question make more sense now? It's not a situation I am actually facing... it was just easier to rephrase the question that way (already checked to make sure of that

So what. You act according to your view of best practices within the regulatory framework of the day. If that framework changes that is not your problem. If you know of such a case you could notify that customer of the ramifications of the change wrt his/her situation, but at the end of the day it is not your responsibility. Your seal certifies that the pack left your loft appropriately serviced within the reg framework of the day, nothing more.

[peregrinerose 0]

There are more ramifications than that... isn't the pilot technically responsible for the rigs in the plane? Theoretically, could the pilot catch shit for the rig in the loophole I described? Say the jumper goes in during the month of January with said loophole.... that's going to open a can of worms.

I have no problem with the 180 day repack, I do have a problem with the loophole created by grandfathering in pack jobs done under the 120 days for this reason.

Besides, I have an over-active sense of responsibility. I'm glad I'm not going to have any rigs caught in that loophole.

Do or do not, there is no try -Yoda

[Andrewwhyte 1]

I am pretty sure even the most anal of FAA types will not venture down that road.
PS the out of date Cypres will still work or else it will fail the self diagnostic; same with the batteries.

[Gary73 10]

Jen,

I don't think that I missed what you're saying. Legally, we are only responsible for making sure that the rig is legal on the day it's signed and sealed. Ethically, I'd say that we're obligated to ensure that the owner understands the particular situation. After that it's their responsibility.

As for the pilot's responsibility, unfortunately the FARs don't really recognize the difference between a pilot keeping an emergency rig in the plane and a pilot hauling jumpers. The FAA should really codify what is already the real-world rule, namely that skydivers are solely responsible for their own gear.

"Extraordinary claims require extraordinary evidence." - Carl Sagan

[dpreguy 14]

[wolfriverjoe 1,523]

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There are more ramifications than that... isn't the pilot technically responsible for the rigs in the plane? Theoretically, could the pilot catch shit for the rig in the loophole I described? Say the jumper goes in during the month of January with said loophole.... that's going to open a can of worms.

This is a good point.
Yes, the pilot is responsible (105.43). Isn't that why DZs do gear checks? And aren't Cypress battery/4yr check dates on the reserve repack card? Mine are. DZs will just have to be careful to make sure that ALL parts of the gear are in date. I would hope for their sake that they do that already, not just look at the last repack date.

"There are NO situations which do not call for a French Maid outfit." Lucky McSwervy

"~ya don't GET old by being weak & stupid!" - Airtwardo

[dpreguy 14]

Called SSK talked with Eric C. He has not received any position statement form Airtecgmbl. I asked him to get his company to make a definitive statement. It would help if they would.

Then called my FAA FSDOand he opined it was the airman's/parachutist's responsibility if a governmental rule change causes something to "time out". Not the rigger's reposibility, when it was properly legal/in compliance when the work was performed. This is one FAA official's position, and, makes sense to me.

(I haven't figured out where to do a resume, guess I'll get busy and figure it out. Master rigger, dpre for Colorado, not touting any elaborate background)

[freakflyer9999 1]

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I think you are missing what I was asking....

Let's say I did a repack (this is a hypothetical scenario, not one I'm actually in)- Under the 120 day rule, the repack would expire Dec 20th.

On this particular rig, the cypres1 goes out of date (12 years plus 3 months, so DOM September 1996) December 2008.

Since the repack now gets an extra 60 days, the repack date moves to Feb 2009. However, the cypres 1 is out December 2008.

That means that the cypres is being used outside the manufacturers requirements with my seal on the container.

Had I known that the effective date for the 180 days was Dec 19 prior to doing the repack, I would not have repacked the reserve with that cypres, knowing that it would have to go out of service during the 180 day cycle However, since it would have been ok for the 120 day cycle, it was packed.

Does the question make more sense now? It's not a situation I am actually facing... it was just easier to rephrase the question that way (already checked to make sure of that

Technically speaking a rigger could repack and sign off on a rig with a Cypres and/or battery due to expire tomorrow. The rig would be airworthy for 1 day regardless of the 120/180 day rule. The rigger is attesting to the rigs airworthiness at the moment, not any particular timeframe into the future.

Any number of things could cause a rig to become unairworthy in the future. The rigger has no control or legal responsibility over those issues. If you disagree, show the regulation that states differently.

Now for the real world, a rigger has a responsibility to his customers to address issues of Cypres expiration, etc. Your rigger should be your partner in maintaining your gear. You and your rigger should both be aware of known issues that may affect the air worthiness of your rig.