How would you deal with this?

[masterrigger1 2]

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That is a perverse reading of 65.125(b)(2) which allows master riggers to supervise packing, maintaining, and altering. To accept that reading, you have to sever the supervision for packing into one class of supervision, and maintaining/altering into another class of supervision. There is nothing in any legislative history, rule-making, or legal action that supports that separation.

per·verse (pr-vûrs, pûrvûrs)
adj.
1. Directed away from what is right or good; perverted.
2. Obstinately persisting in an error or fault; wrongly self-willed or stubborn.
3.
a. Marked by a disposition to oppose and contradict.
b. Arising from such a disposition.
4. Cranky; peevish.

I really thinkk you are going after #1, but maybe #2 here with the word "preverse".

In any case, you are assuming in your theories that the work preformed for training is to be used and the Regs are at fault or error. It is a flawed theory...

The way it was explained to me, at a meeting about 6 years ago, the work for training (packing) is "Not for Use".

The reason why is that the packing process is believed to be a continual inspection throughout the packing process. The certificate holder,(rigger), is the only one that can legally do inspections "for use".

The same applies to an AI for annual inspections for aircraft. He/she cannot allow another person to do inspections for "return to service" work or inspections unless he/she follows up with their own inspections.

With parachute packing, there is no way a post inspection can be preformed, so it cannot be legal.
This was explained to me, in detail, by lead FAA personnel at a DPRE recurrent seminar.

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Will you be at the PIA meeting in a couple weeks? I asked MEL and got . . . silence.

Mark,
I replied, just do not know why the post is not there.

But, I intend on being there..........

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[pchapman 279]

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With parachute packing, there is no way a post inspection can be preformed, so it cannot be legal.
This was explained to me, in detail, by lead FAA personnel at a DPRE recurrent seminar.

Why is lack of a POST inspection a problem, as long as the inspection is DURING?

One could easily have maintenance on an aircraft where major disassembly is required. A part gets inspected, everything gets put back together, and it becomes very expensive to rip everything apart again to inspect a 2nd time. Inspection ports & borescopes don't allow access to everything.

E.g., What are the rules for A&P aircraft mechanic trainees reassembling an engine? Do they work under supervision or do they assemble & disassemble some old engine in the corner of the shop repeatedly?


I can't expect you to know what goes on in the hearts & minds of the FAA, but it seems like a lame excuse on their part. Everyone knows parachute packing has to be supervised at a number of stages because obviously you can't check it non-destructively when it's in the container.

(I'm in Canada we don't have this issue; trainee riggers are allowed to pack under supervision for use.)

It sounds like it is only relatively recently that the word has been getting out that technically in FAA-land, the pack jobs under supervision have to be dummy packs.

So I wonder what proportion of new FAA certified riggers have been doing dummy packs vs. placed-in-service packs? Have they been doing dummy packs only recently? Is it a phenomenon that has only become common in the era of big, formal, expensive rigger courses? (Mind you, for such courses, one pretty much has to do dummy packs -- if you have 6 riggers trying to do all their pack jobs in 2 weeks or what have you, that's a lot of rigs to pack.)

[masterrigger1 2]

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Why is lack of a POST inspection a problem, as long as the inspection is DURING?

I have no idea why they wrote it that way.

But, because there are no provisons of supervision, for a parachute intended for use,it makes it illegal if supervised and used.

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One could easily have maintenance on an aircraft where major disassembly is required. A part gets inspected, everything gets put back together, and it becomes very expensive to rip everything apart again to inspect a 2nd time. Inspection ports & borescopes don't allow access to everything.

This is why they use mockups or "for training only" engines in the AP schools.

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It sounds like it is only relatively recently that the word has been getting out that technically in FAA-land, the pack jobs under supervision have to be dummy packs.

So I wonder what proportion of new FAA certified riggers have been doing dummy packs vs. placed-in-service packs? Have they been doing dummy packs only recently? Is it a phenomenon that has only become common in the era of big, formal, expensive rigger courses? (Mind you, for such courses, one pretty much has to do dummy packs -- if you have 6 riggers trying to do all their pack jobs in 2 weeks or what have you, that's a lot of rigs to pack.)

I used old B-12's and NB-6 rigs that were not airworthy when I did my back and chest certificates.

It was the norm back in the day to use un-airworthy rigs for your pack jobs.

It still is at most rigging school courses today, but they are using more modern un-airworthy gear.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerrob 643]

Sounds like sea-lawyering to me!

There is a far more pragmatic reason for apprentices not bragging about whose parachutes they packed.
If a student ever gets injured, lawyers will be all over the apprentice rigger like sharks on a wounded fish!

I have no objections to people jumping reserves packed by my apprentices, BUT I tell apprentices not to brag until AFTER they earn the license.

To that end, I rarely ask apprentices to pack more than 20 or 25 reserves before testing for their FAA Senior Rigger license. Any more than 25 and something is amiss.

[RiggerLee 61]

I think this is a fundomenally flawed idea. I learned in exactly the oposit manner. I worked in a loft sewing and was eventually trained as a rigger. Over the course of time I had the opertunity to see all kinds of things. Drag chutes for lear jets, ejection seats, hang glider reserves, not to mention just about every PEP and old sport rig on the market. I think I receaved a very good education as a rigger in a reletively short time. That being a couple of years. And in fact found that I was continuing to learn after I left there. Even with all I was exposed to there at one of the bussiest lofts in the state I've continued to run in to new supprises over the years. The concept of trying to compress all of that into a two week course seems like a poor substitute for the training I was lucky enough to receave. That couldn't have happened if I was just over in a corner of the shop playing with toy rigs. I don't think any one could have a collection large enough or varried enough to match what I was exposed to there. I don't think twenty pack jobs is enough to qualify some one to even be a senior rigger. Not allowing some one to work under suppervision makes the possibility of that kind of appenticeship imposable. at that point your down to a two week rubber stamp course and lets face it that doesn't make you a real rigger. I've known people that have done it and eventually gone on to become good riggers but I still think that it is an inharently infearier way to learn.
In short this is some thing that is fucked up that we should fight to change.

Lee

Lee
lee@velocitysportswear.com
www.velocitysportswear.com

[riggerrob 643]

Agreed!
The best education starts with packing twenty-ish reserves - under supervision, passing the exam, then continued apprenticeship.
The continued apprenticeship allows young riggers to earn some money (doing I&Rs) and an opportunity to see a wider variety of parachutes.
The apprenticeship should be in a busy loft, under the supervision of a Master Rigger/Rigger Instructor/Rigger Examiner who enjoys teaching.
It also requires a loft owner who is willing to pay the Master Rigger for the time he/she spends coaching.
Sadly, not all loft owners/DZOs understand the long-term benefits of upgrading or promoting existing staff.

For example, I earned my first rigger (CSPA Rigger A) rating during a three weekend course, and hobby-rigged for a few years.
Earning my FAA Senior Rigger rating involved little additional tutilege, frankly, little more than testing with Dave DeWolf. to his credit, Dave taught me several new points during my practical test.
I learned the most about Pilot Emergency Parachutes during the year I worked at Butler Parachute Systems.
A few years rigging for Square One (Perris Valley, California) exposed me to the full diversity of sport parachutes.
Three years with Rigging Innovations taught me most of what I needed to know about harness and container sewing.

[Unstable 9]

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Will you be at the PIA meeting in a couple weeks? I asked MEL and got . . . silence.

Sorry for the late Reply - No, I will not be at the PIA meeting this year, although I've gone in years past and I hope to go next year.

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I don't understand exactly what the problem is. Is there a safety issue here? Or is there just some sea-lawyering gone overboard? The FAA has some leeway here; there is ambiguity in the regulations. We ought to be helping the FAA interpret that ambiguity broadly to our advantage.

Agrees, There is a lot of Sea Lawyering going on here, and I'll try to make the point I have (and from reading the posts here from the last few days, probably the same point others are making, if not from a different angle.
From my experience (Same general approach to the FAR) a lot of questions get raised - I tend to default to the most conservative approach. If the 'jump' which RiggerLee mentioned was applied to other sections of 92, 65, 111, then I see a lot more leaway in ways which Frankly I don't want to see. I'm a simple guy - I've found in my profession (Quality Engineering) audit points and issues occur when we don't read a document literally.

=========Shaun ==========

[NovaTTT 2]

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Agrees, There is a lot of Sea Lawyering going on here, (- snip -) From my experience (Same general approach to the FAR) a lot of questions get raised - I tend to default to the most conservative approach.

I think it is that one must connect the dots to understand what is the intent. Can't find your way through FARs? Thank a lawyer.

Summarization of this aspect of thread:

Part 65.111(a) clearly states only a certificated and type-rated rigger may pack parachutes intended for emergency use in civilian aviation. This includes sport reserves.

Part 65-125-65 indicates privileges, which include supervision for packing any parachute for which the rigger has a type rating, specifically related to Parts 105.43(a) and 105.45(b)(1), which regulate the use of sport and tandem mains.

So I believe the intent is there:

1 - A rigger may supervise the packing of main parachutes if the rigger has that type rating. So, for example, getting only the "easy" chest rating to supervise the DZ packing floor isn't going to work.

2 - Riggers may supervise reserve packjobs for the types for which they hold a rating, but those rigs may not be used "live", according to 165.111(a).

But I'm not from the FAA.

"Even in a world where perfection is unattainable, there's still a difference between excellence and mediocrity." Gary73

[mark 107]

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A rigger may supervise the packing of main parachutes if the rigger has that type rating. So, for example, getting only the "easy" chest rating to supervise the DZ packing floor isn't going to work.

Sport mains are not back type parachutes. The FAA uses the word "type" to mean something different than the casual civilian use synonymous with "kind," "sort," or "style." Only reserve parachutes are typed.

No type rating is required to supervise main packing. 65.125(c) exempts riggers from the requirement to have a type rating to pack main parachutes.

Mark

[Unstable 9]

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2 - Riggers may supervise reserve packjobs for the types for which they hold a rating, but those rigs may not be used "live", according to 165.111(a).

But I'm not from the FAA. Wink

Had a heart-to-heart with our FSDO guy about that - He was tasted to supervise DZ's and Riggers in the area and the FAA sent him to Idaho and MOntana for a year to rig up there for the smoke jumpers to learn the lingo - my point being that I believe your interpretation is similar to the FAA's...

=========Shaun ==========

[mark 107]

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2 - Riggers may supervise reserve packjobs for the types for which they hold a rating, but those rigs may not be used "live", according to 165.111(a).

But I'm not from the FAA. Wink

Had a heart-to-heart with our FSDO guy about that - He was tasked to supervise DZ's and Riggers in the area and the FAA sent him to Idaho and MOntana for a year to rig up there for the smoke jumpers to learn the lingo - my point being that I believe your interpretation is similar to the FAA's...

May master riggers supervise repairs made to "live" rigs?

Mark

[NovaTTT 2]

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No type rating is required to supervise main packing. 65.125(c) exempts riggers from the requirement to have a type rating to pack main parachutes.

Mark

Yes, but this, I think, is the heart of the "dirty language" in re this issue. FAR 65.125.a.2 indicates a rigger may "Supervise other persons in packing any type of parachute for which that person is rated in accordance with Part 105.43.a and Part 105.45.b.1"

That means a chest main, a back main, a seat main, or a lap main.

So I stand by my interpretation of the intent, based on the current language. The FARs seem to indicate something we know is not the case, that mains are worn on the back and not being TSO'd or certificated, are not type rated.

Tell it to the FAA - it's their book and their language.

I don't mind other interpretations, and I don't mind being wrong. I mind the FARs being unclear and/or erroneous.


ETA: But I'm still not from the FAA

"Even in a world where perfection is unattainable, there's still a difference between excellence and mediocrity." Gary73

[riggerrob 643]

"... May master riggers supervise repairs made to "live" rigs?

Mark

[riggerrob 643]

From my perspective, then INTENT of the law is to prevent Master Riggers from abusing the system by forcing rigger apprentices to pack a few hundred reserves "under supervision" before recommending them to test for Senior Rigger rating.

Regional opinions vary.

For example, I once got fired for trying to import Southern California standards to another state. The second state got miffed when I refused to sign on top of an apprentice's pack jobs.
Once it became clear that he had no intention of testing for an FAA Senior Rigger rating, I lost interest.
It was also clear that he believed that he had nothing to learn from me, a Master Rigger.
Eventually his rigging practices resulted in a recall (of ripcords) and the replacement of a few dozen damaged pilot chutes, but I got fired over our personality clash.

[mark 107]

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"... May master riggers supervise repairs made to "live" rigs?

Mark

..."

..........................................................................

Yes!
It is part of the learning process for Senior Riggers to become Master Riggers.
Young riggers start by sewing simple patches to the middle of canopy panels. After a few dozen simple sewn patches, then they sew a few patches - including re-sewing seams - under the supervision of a Master Rigger. Eventually, they do complex patches - involving seams, tapes and line attachment points - under the supervision of a Master Rigger.
As long as the Master rigger is willing to sign off the repair, it is legal.
Eventually, the Senior Rigger tests to become a Master Rigger, but the bottom line is that you have to sew a few hundred patches before you can test for Master Rigger.

[masterrigger1 2]

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May master riggers supervise repairs made to "live" rigs?

Yes.
The difference is that there is not a rule that states the person doing the repairs has to have a certificate.


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 107]

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May master riggers supervise repairs made to "live" rigs?

Yes.
The difference is that there is not a rule that states the person doing the repairs has to have a certificate.


MEL

I'm trying to establish the meaning of "supervise." What is the difference between "supervise" in the context of repairs, and "supervise" in the context of packing? The clause in the regulation uses "supervise" only once. Does the meaning of the word change after a comma?

Mark

[masterrigger1 2]

Mark,
I see where you are going with it, but I believe that it is a dead-end road.

The word and definition of "supervise" is not going to change. The tasks involved and allowed will.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 107]

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The word and definition of "supervise" is not going to change. The tasks involved and allowed will.

I don't understand what you mean by this, except possibly that the meaning of "supervise" changes to "train" when it comes to packing.

Mark

[riggerrob 643]

"Supervise" means that the "supervising" rigger must be in the same room, visually monitoring work and be available to answer questions.
Initially, this requires explaining and carefully observing every step, but as apprentices improve, they need less and less supervision.
For example, late in the learning process, I casually glance over occassionally and only offer minor suggestions.

But let's remind ourselves that the FAA's original intention of "packing under supervision" was primarily to train new riggers.
If a rigger apprentice packs more than 30 reserves "under supervision," something is wrong. Either the apprentice is a slow learner, or he/she is being used as slave labour.

[mark 107]

Rob -- I think you and I agree. I'm just trying to get MEL's take on this, why the meaning of "supervision" should change between the beginning of 65.125(b)(2) and the end. I think he's saying it has two different meanings even though it is used only once. It sounds like the Red Queen in Alice in Wonderland, "It means what I say it means. . ."

Mark

[riggerrob 643]

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May master riggers supervise repairs made to "live" rigs?

Yes.
The difference is that there is not a rule that states the person doing the repairs has to have a certificate.


MEL