howardwhite 6 #101 December 7, 2008 Quoteit was kim.a.barnette@faa.gov who is listed on the FAA docket for questions. Interesting. He was the guy who met with people from USPA and PIA on Nov. 19. You quote his email as: QuoteThe way the rule is written all sport, emergency and reserve parachutes automatically to 180 days on December the 19th. This sentence does not quite make grammatical sense; is it an accurate representation of his mail? Also you quoted: Quoteyou can go back to jumping the parachute on the 18th of December I assume he meant the 19th of December. HW Quote Share this post Link to post Share on other sites
ozzy13 0 #102 December 8, 2008 Why cant you repack the rig and make a note that the batteries are due and when if they are due before the next repack?Never give the gates up and always trust your rears! Quote Share this post Link to post Share on other sites
jojo0815 0 #103 December 8, 2008 This sentence does not quite make grammatical sense; is it an accurate representation of his mail? *** yes that is copied from the email. Quote Share this post Link to post Share on other sites
mark 107 #104 December 8, 2008 QuoteWhy can't you repack the rig and make a note that the batteries are due and when if they are due before the next repack? Some of us (including me) do that and would have made a note for batteries or other maintenance due between November 19 and January 18 if we had known in time. Since we did not know in time, some of our less aware customers might jump a rig that has maintenance due before the end of the new 180-day pack cycle. A few of us (not including me) think there is legal liability attached to the lack of a note on the packing data card, hence the concern. Mark Quote Share this post Link to post Share on other sites
tdog 0 #105 December 8, 2008 QuoteThe rule is that all components must meet manufacturers guidelines for the full pack cycle. So the batteries must be changed if they expire before the pack cycle does. I don't think it is difficult for people to understand. Read this post by SSK. MEL will argue that SSK is not the manufacture and simply a "service center", but they are the ONLY and OFFICIAL service center for the USA, so I think that makes them able to speak on behalf of the manufacture more than you, me, or any other rigger... http://www.dropzone.com/cgi-bin/forum/gforum.cgi?post=2385171;#2385171 You say: QuoteI don't think it is difficult for people to understand. It must be pretty difficult because you posted something completely contradictory to the manufacturer's authorized service center's instructions and answers. That is the debate. So, I challenge you to cite the exact rule that specifies what you said. I have been looking for it for days. Quote Share this post Link to post Share on other sites
lonelymoose 0 #106 December 8, 2008 QuoteQuote 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." Am I reading the regs correctly? 1) Reserves for single harness systems AND dual harness systems (tandem) have to be packed within the previous 180 days. 2) Main canopy on a single harness system ONLY must have been packed within the previous 180 days. 3) Main canopy on a dual harness system has no requirement to have been packed in any timeframe???? §91.307 Parachutes and parachuting. only refers to parachutes for emergency use (reserves) §105.43 Use of single-harness, dual-parachute systems. only refers to single harness systems. §105.45 Use of tandem parachute systems. refers back to §105.43 and only pertains to reserve parachutes. Is this common knowledge and has this always been the case? Or am I just missing something? Quote Share this post Link to post Share on other sites
councilman24 37 #107 December 8, 2008 The comment about tandem mains to the FAA was mine. They left it out when they wrote tandems into 105 in 2001. I was just trying to get them up to speed, but they rejected it on the false premise that the rule making didn't affect tandems. As stated it does by reference. Oh well, I tried.I'm old for my age. Terry Urban D-8631 FAA DPRE Quote Share this post Link to post Share on other sites
masterrigger1 2 #108 December 9, 2008 *** Read this post by SSK. MEL will argue that SSK is not the manufacture and simply a "service center", but they are the ONLY and OFFICIAL service center for the USA, so I think that makes them able to speak on behalf of the manufacture more than you, me, or any other rigger... *** Travis, Show us where anyone other than the manufacturer is eligible to speak their behalf in the regs. The regs speak of the manufacturer and no one else; i.e. no provisions for "in lieu of". The post made by Cliff also has a few quotes that are outside of the jurisdiction of the manufacturer, let alone SSK. The FAR's tell the rigger how to record the data, not a manufacturer. Also, the conditions for packing a parachute systems are setforth by the FAR's, not a manufacturer. Hopefully it all will be settled by week's end( I hope). BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
tdog 0 #109 December 9, 2008 Quote Travis, Show us where anyone other than the manufacturer is eligible to speak their behalf in the regs. The regs speak of the manufacturer and no one else; i.e. no provisions for "in lieu of". Well, one could equally argue that a factory authorized service center representative, per the manufacturer's documentation who is officially delegated with the exclusive responsibility to maintain, service and sell the equipment in a certain geographic part of the world, IS acting as the manufacture. But because I like covering my bases - I just might email "the manufacture". Quote Also, the conditions for packing a parachute systems are set forth by the FAR's, not a manufacturer. Except for when the FAR says it must be maintained in accordance with manufacturer's instructions. Otherwise... Perfect - we agree... So, please show me the exact FAR that says that an AAD equipped rig must be "airworthy" for the entire upcoming "pack window" for a Rigger to pack it and seal it. I think at this point - neither one of us have an FAR that supports our belief - so we are left with how we choose to interpret the ambiguity. You never replied to my previous request to share the exact wording you sent to the FAA regulator, for which you expect a reply this week.... When you do get a reply from the FAA, would you mind sharing the entire chain of conversation? Quote Share this post Link to post Share on other sites
masterrigger1 2 #110 December 9, 2008 Travis, You missed the fact that on your next to last post you gave an opinion without written documentation. (In fact we have the exact opposite in the FAR's) Then, you preceeded to ask the gentleman to show us written proof for his belief. Quote Quote -------------------------------------------------------------------------------- Also, the conditions for packing a parachute systems are set forth by the FAR's, not a manufacturer. -------------------------------------------------------------------------------- Except for when the FAR says it must be maintained in accordance with manufacturer's instructions. So who setforth that rule? Answer. The FAA *** You never replied to my previous request to share the exact wording you sent to the FAA regulator, for which you expect a reply this week.... When you do get a reply from the FAA, would you mind sharing the entire chain of conversation? Quote The reason that I never replied is very simple. I believe that your request to view my email is very unreasonable as some are written on a personal level. I do intend to share the ones that where not written in a personal level and have content that is valuable to the community. BS, MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
riggerpaul 1 #111 December 9, 2008 So please put the whole issue to rest - tell us the FAR that supports your statement. If it isn't written, it isn't law. Anecdotes don't make it law. The opinion of any particular FAA representative doesn't make it law. A long history of doing it this way doesn't make it law. If it isn't written, it isn't law. Tell us which law which establishes the requirement and the discussion will be over. Please, ANYONE who says that the battery must stay legal through the cycle, tell us the law. I don't want to be breaking the law, honestly I don't. But I need to see the relevant law to believe it. Quote Share this post Link to post Share on other sites
Communications 0 #112 December 10, 2008 In consultation with the FAA and the Parachute Industry Association, USPA has developed answers to some obvious questions on USPA’s blog. Rig owners with specific questions about their rigs should consult with their riggers and/or the manufacturer of a specific component. (Technical or rigger-related questions posed on USPA’s blog will be forwarded to PIA or the component manufacturer, if USPA is not able to answer with certainty.) Randy Ottinger USPA Director of Government Relationswww.uspa.org Read the USPA blog! Quote Share this post Link to post Share on other sites
pchapman 279 #113 December 10, 2008 QuoteIn consultation with the FAA and the Parachute Industry Association, USPA has developed answers to some obvious questions on USPA’s blog. That document says that it is OK for riggers to pack up a reserve where the AAD or battery will expire before the 180 days, although it strongly suggests the rigger write down those limits. While the USPA is not guaranteed to be correct about everything FAA related, this still goes against the theory that masterrigger1 had been proposing. Quote Share this post Link to post Share on other sites
masterrigger1 2 #114 December 11, 2008 Quote That document says that it is OK for riggers to pack up a reserve where the AAD or battery will expire before the 180 days, although it strongly suggests the rigger write down those limits. While the USPA is not guaranteed to be correct about everything FAA related, this still goes against the theory that masterrigger1 had been proposing. Peter, It never speaks of the repacking process, just if the AAD has issues before the end of the 180 days. This is of course a rig packed before December 19th. I looks as if it is only addressing the entrance or begining of the 180 day rule and it's issues. It is also a USPA-PIA interpertation and not a FAA one. Another point, I don't know how old their information is. BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
pchapman 279 #115 December 11, 2008 Quote It never speaks of the repacking process, just if the AAD has issues before the end of the 180 days. This is of course a rig packed before December 19th. I looks as if it is only addressing the entrance or begining of the 180 day rule and it's issues. You're right. Yet while it is part of a discussion about Dec 19 changes specifically , the question & answer paragraph reads as if it could apply at any time in the future. The debate continues. Quote Share this post Link to post Share on other sites
howardwhite 6 #116 December 11, 2008 I'm posting this wearing my hat as the public info dude for PIA: 180-day repack FAQ for Riggers: http://www.pia.com/piapubs/PIA-180FAQ.pdf 180-Day Repack Answers for Skydivers (already posted above by USPA): http://skydiveuspa.wordpress.com/2008/12/10/180-day-repack-answers The USPA Repack Answers and PIA FAQ for Riggers were developed by USPA's Executive Director & Director of Government Relations, and PIA's President; reviewed by PIA's Technical and Rigging Committee Chairs, and the FAA. HW Quote Share this post Link to post Share on other sites
riggerpaul 1 #117 December 11, 2008 QuoteI'm posting this wearing my hat as the public info dude for PIA: 180-day repack FAQ for Riggers: http://www.pia.com/piapubs/PIA-180FAQ.pdf 180-Day Repack Answers for Skydivers (already posted above by USPA): http://skydiveuspa.wordpress.com/2008/12/10/180-day-repack-answers The USPA Repack Answers and PIA FAQ for Riggers were developed by USPA's Executive Director & Director of Government Relations, and PIA's President; reviewed by PIA's Technical and Rigging Committee Chairs, and the FAA. HW The PIA document (http://www.pia.com/piapubs/PIA-180FAQ.pdf) has the following question and answer: Quote Q: Is it legal for a rigger to pack a parachute if the AAD will need required service (or reach end of life, etc.) prior to the next required reserve repack date? A: We have been informed by the FAA that "This rule (180-day repack) makes no changes with the AAD's. Say the battery comes due before the repack is due, it still has to be replaced on schedule." FARs 105.43 and 105.45 require that the "person" (skydiver or tandem instructor as appropriate) ensure that the AAD is maintained on schedule. Riggers should record next AAD service date(s) on the packing data card, so that the "person" can easily make this determination. However, if an individual rigger does not want to pack a reserve when the AAD will not by airworthy the entire repack cycle, that certainly is his option. Okay, I'll admit it doesn't actually answer as directly as I would like. I certainly would have preferred if the answer had been a simple "Yes". But I'm pretty sure they just said that it is, and always has been, legal to pack that rig. Quote Share this post Link to post Share on other sites
howardwhite 6 #118 December 11, 2008 Quote ...will not by airworthy... Typo has been fixed.HW Quote Share this post Link to post Share on other sites
riggerpaul 1 #119 December 11, 2008 That text was cut-and-pasted from the PIA document. Is that where you fixed it? (I totally missed that typo error when I was copying it from the doc. Thanks!) Quote Share this post Link to post Share on other sites
masterrigger1 2 #120 December 11, 2008 Quote But I'm pretty sure they just said that it is, and always has been, legal to pack that rig. Paul, The FAA has it in the Legal department right now. They do not even know if it is leagl or not, so it could go either way. They are going to put it into AC-105 though when done. So look there in a few days. Also, again the document from USPA and PIA is just that. Not one from the FAA...and the FAA has some disagreements in-house it seems. BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
riggerpaul 1 #121 December 11, 2008 Okay. My anecdote is really no better than your anecdote.When do you think AC 105-2D will come out? I had heard that we should not expect it until during or after the upcoming symposium, February 2009. I hope we'll have an authoritative answer before then. Quote Share this post Link to post Share on other sites
howardwhite 6 #122 December 11, 2008 QuoteThat text was cut-and-pasted from the PIA document. Is that where you fixed it? I didn't make the typo, but I notified the person who did and she fixed it. HW Quote Share this post Link to post Share on other sites
masterrigger1 2 #123 December 11, 2008 Quote When do you think AC 105-2D will come out? I have no earthly idea. After today, I ve got the destinct feeling no one person has the same game plan up there! They are more confused than we are! BS, MELSkyworks Parachute Service, LLC www.Skyworksparachuteservice.com Quote Share this post Link to post Share on other sites
riggerpaul 1 #124 December 11, 2008 Quote They are more confused than we are! Hey! Who you callin' confused?!? I'm not confused!!! You confused? Didn't thin' so. Quote Share this post Link to post Share on other sites
councilman24 37 #125 December 11, 2008 I expect that it will be much longer than Feb 2009 for Ac 105 2D. The feds are writing part, USPA is writing part, and some of us at PIA are writing part. Concensus will take a lot longer than the next PIA business meeting. Which is the real key not the symposium.I'm old for my age. Terry Urban D-8631 FAA DPRE Quote Share this post Link to post Share on other sites
