Who should reline a canopy? Rigger? Master Rigger? Factory?

[masterrigger1 2]

Billvon,
It seem that some people do not read the instructions or "line maps' as we call them.
A lot of riggers have installed PD line sets out theremore so than any other canopy.
They (PD) label their lines differently than most other manufacturers. The riggers are assuming that the lines are labeled the same on all canopies and they are not..
The next thing is the equipment. Sewing will shrink the line or lines. If a zig-zag is used , it most be the same stitch length at all places that it is used or you can have differental line lengths. The most preferred method is of course a bartack. But I have even seen a mis use of that. A rigger had bought a bartack set up for drapery work. It had avery long stitch (about 3 inches). That stitch shrunk the line length down over 2 cm. Our tolerence on Vectran line canopies (new line sets) is 2 mm.
Line work is getting more and more precise and demanding as the canopies evolve.The people installing or making line sets need exact training and the proper equipment. You will be seeing some changes in the industry regarding this issue in the very near future.


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[livnbored 0]

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A. An alteration to an approved parachute system used for intentional jumping must be done in accordance with approved manuals and specifications and only by those with specific authorization to perform that alteration. Specific approval is not needed for the method of altering a main parachute.

Basically, what specific authorization means is when the alteration is not listed in any manual you generally need written approval from the manufacturer in order to perform the alteration...generally it is backed up with you own written agenda and how you will go about doing this alteration. Then you get something called approval when you go ahead and do your "alteration". A line set does not need to be authorized.

MEL you make good points. I remember in the rigging course everyone having questions about lines, luckily we had good teachers.

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[Hooknswoop 19]

masterrigger1 wrote:

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The ruling for alterations to main parachutes is forth coming from Washington and will be posted when I receive it. It has not changed!

and;

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Again, expect the formal written version Mid-January.

Well it is now April 19th. Any official word from the FAA yet?

Who within the FAA can I contact to inquire about the FAA’s ruling on Part 65.111? Phone # or e-mail?

Derek

[Hooknswoop 19]

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This is why I have directed the ruling from the FAA to go to you as soon as possible and have asked for re-training for your local Inspector. The ruling is expected mid-January.

I haven't received anything from the FAA. I would like to question the FAA office you contacted and ask them why, after over 4 months, they still have not issued an official ruling re: Part 65.111. I think 4+ months, especially after given the expectation that it would be issued in less than 1 month, is an absurd length of time for a simple ruling.

Derek

[masterrigger1 2]

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Again, expect the formal written version Mid-January.

Well it is now April 19th. Any official word from the FAA yet?

Who within the FAA can I contact to inquire about the FAA’s ruling on Part 65.111? Phone # or e-mail?

Derek

[Hooknswoop 19]

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As you already know I have emailed you with that information before. If you need it again I will email it yet again!

The only e-mail address I recieved was from another Inspector, who didn't return my e-mail. I didn't recieve any contact info for the official ruling.

Derek

[masterrigger1 2]

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This is why I have directed the ruling from the FAA to go to you as soon as possible and have asked for re-training for your local Inspector. The ruling is expected mid-January.

I haven't received anything from the FAA. I would like to question the FAA office you contacted and ask them why, after over 4 months, they still have not issued an official ruling re: Part 65.111. I think 4+ months, especially after given the expectation that it would be issued in less than 1 month, is an absurd length of time for a simple ruling.

Derek

Derek,
You can help expedite the process all that you want, I would appreciate the help!
For your information, it is not just 65.111 that is being ruled upon.
I will send a another PM.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[PhreeZone 20]

Please feel free to post the offical ruling. Its more then just Derrek thats wanting to know about this.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[linestretch 0]

so ummmm.....what was the ruling on this one.


....waiting as I relign my canopy.

my pics & stuff!

[rhys 0]

i reline my own canopies. it is not hard if you have a good strong sewing machine and can make a bar tack.

$60 is very cheap and if someone has a master riggers rating then they will be able to do it no problem.

"When the power of love overcomes the love of power, then the world will see peace." - 'Jimi' Hendrix

[Hooknswoop 19]

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so ummmm.....what was the ruling on this one.

I keep e-mailing the FSDO for a status of my request without reply. It has been 6 months since I mailed the request in with no word. I'll try calling today.

Derek

[riggerrob 643]

I thought that we beat this horse to death a decade ago.
FARS clearly state that major repairs (i.e. replacing a suspension line) can only be done by an FAA Master Rigger or the manufacturer.

Our current problem is that some one has their own weird and wonderful interpretation of the FARS and will continue to re-ask the question until someone tells them what they want to hear.
Stop annoying the FSDO, they might bite back.

[PhreeZone 20]

With the latest rewrite of the FAR's I thought the wording has changed in reguards to the main.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[beezyshaw 0]

I just skimmed over this thread again, since it has been bumped back up to the top of the forum. I don't recall reading this interpretation anywhere (maybe I just missed it), but the way I interpret FAR 65.111(b) is...
If you are going to reline a main canopy, you should be a master rigger or under the supervision of one; OR you must be the person that is to make the next jump on the canopy.
I guess the reason I get that interpretation is the use of the word "appropriate" certificated rigger. But then again, to stir the pot a little more, 65.111(b)(2) could be interpreted to mean that ANY certificated rigger could supervise someone altering a main canopy, since that clause doesn't include the word "appropriate" !!

[Hooknswoop 19]

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FARS clearly state that major repairs (i.e. replacing a suspension line) can only be done by an FAA Master Rigger or the manufacturer.

No, they don't. The Master Rigger/Inspector at the Denver FSDO says that is not the case. I requested a Legal Intrepitation from the FAA.

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Our current problem is that some one has their own weird and wonderful interpretation of the FARS

By someone, you mean the Inspector/Master Rigger at the Denver FSDO?

Here is the e-mail I recieved from the FSDO:

"14 CFR Part 65.111(b) states, "No person may pack, maintain, or alter
any
main parachute of a dual-parachute system to be used for intentional
parachute jumping in connection with civil aircraft of the United
States
unless that person ?
1. Has an appropriate current certificate issued under this subpart;
2. Is under the supervision of a current certificated parachute
rigger;
3. Is the person making the next parachute jump with that parachute
in
accordance with 105.43(a) of this chapter;
4. Is the parachutist in command making the next parachute jump with
that parachute in a tandem parachute operation conducted under
105.45(b)(1)
of this chapter."

In plain language this regulation states:
1. If you have a parachute rigger certificate or
2. You are under the supervision of a parachute rigger or
3. You are the person jumping with the main parachute or
4. You are the parachutist in command making the next tandem jump
with
that main parachute

So, if you are any one of the above, you can pack, maintain, or alter
any
main parachute of a dual parachute system.

However, keep in mind that any main parachute alteration that affects
the
strength or operation of the auxiliary (reserve) parachute, including
the
harness, must be regarded as an alteration of the auxiliary (reserve)
parachute and must be performed by a Master Parachute Rigger using FAA
approved data.

This also answers your question that you can change how the main
parachute
is packed if you are one of the items above.

Hope this clearly answers your questions."

Derek

[scdrnr 0]

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FARS clearly state that major repairs (i.e. replacing a suspension line) can only be done by an FAA Master Rigger or the manufacturer.

But, as Hooknswoop states, other FARs clearly state that main parachutes may be maintained and altered and packed by others people as well.

When FAR's are vague or contradictory, check the AC for guidance. If that doesn't help then contact your FSDO for guidance. Get their response in writing. Problem solved.

Not all FSDO's will come up with the same interpretation. Doesn't matter - do what your FSDO tells you to. If you get a letter from regional or national, so what. That may supersede any instructions given to you by your FSDO, but unless they send it to me, or disseminate it in some other form such as an AD or AC, it doesn't affect me.

I know everyone wants the FAR's to be black and white and be applied equally everywhere to everyone, but that isn't the case. Different FSDO's will interpret and enforce the rules differently.

[PhreeZone 20]

How do you go about getting a ruling when your region is with out a DPRE?

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[scdrnr 0]

A DPRE is not the one who should ultimately be giving the interpretation, although many FSDO's will rely on their DPRE's for an opinion if they don't have anyone with the applicable knowledge on their staff. If they don't have a rigger on staff or a DPRE, it is up to you to make your case and get them to agree with you in writing. If you want an interpretation of 65.111, show them the text and ask them to tell you what it means. It may help if you provide evidence that the Denver FSDO, which has an Airworthiness Inspector on staff who is a Master Rigger, has made a ruling on the issue in question.

[masterrigger1 2]

Beezy,
you are right again.
The test questions in the faaa written exam help clarify the picture a little.
In essance only a master rigger can modify and alter a parachute --- main or certificated.
as far as the relining, look at AC 105-2C. it tells you plainly that only a master rigger can do major work to a parachute. It gives replacing lines as an example.

The ones that refuse to accept it as read , are generally senior riggers.
Why, I don't know.

As far as the Inspector at the FSDO, I talked to him also and found out he knew very little about rigging.
I believe his field is instruments/avionics??

I aslo have asked for an interpertation and got a written one and a verbal one both reflecting what I have stated above. I had forwarded the email to Derrick some time ago.

I am still waitng for the "formal" one from the FAA legal department in Washington.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[Hooknswoop 19]

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As far as the Inspector at the FSDO, I talked to him also and found out he knew very little about rigging.
I believe his field is instruments/avionics??

Don is a Master Rigger.

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I aslo have asked for an interpertation and got a written one and a verbal one both reflecting what I have stated above.

From an Inspector, same as the one I have. The fact that we have 2 opposite interpretations from 2 Inspectors tells me that the FAR's are not very clear and can be interpreted differently.

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I am still waitng for the "formal" one from the FAA legal department in Washington.

Me too. I am mailing another request, this time directly to Washington, for a formal, FAA legal interpretation. Either way, that will put an end to an interesting debate.

As for AC-105-2C, it defines alterations as changes to the FAA approved configuration. It also lists examples of approved parachutes as parachutes manufactured under a type certificate, under TSO C23, and military parachutes. That excludes mains, by definition.

Derek

[f1shlips 2]

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it tells you plainly that only a master rigger can do major work to a parachute.

I agree. Part 65, Suprart F says:

B. No person may pack, maintain, or alter any main parachute of a dual parachute pack to be used for intentional jumping in connection with civil aircraft of the United States unless he has an appropriate current certificate issued under this subpart. However, a person who does not hold such a certificate may pack the main parachute of a dual parachute pack that is to be used by him for intentional jumping.

You cannot maintain, or alter a main parachute without a rigger certificate. AC-105 gives a line replacement as an example of a major repair which means a master rigger is the only person deemed competant by the FAA.

However, the manufacturer is also allowed to replace lines. I would argue that if the manufacturer sells me a line set he is authorizing me to finish the repair by installing the lineset. That is what makes the major repair legal when done by a senior rigger or whoever. A master rigger would have the authority to create a line or lineset from scratch and install it without the manufacturers approval.

--
drop zone (drop'zone) n. An incestuous sesspool of broken people. -- Attributed to a whuffo girlfriend.

[mjosparky 4]

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A master rigger would have the authority to create a line or lineset from scratch and install it without the manufacturers approval.

If you read down a bit more Part 65 says the following:

§ 65.129 Performance standards.

No certificated parachute rigger may—
(a) Pack, maintain, or alter any parachute unless he is rated for that type;
(b) Pack a parachute that is not safe for emergency use;
(c) Pack a parachute that has not been thoroughly dried and aired;
(d) Alter a parachute in a manner that is not specifically authorized by the Administrator or the manufacturer;
(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute;

This would appear to say that you need approval for anything that is not already in the manual.

Sparky

My idea of a fair fight is clubbing baby seals

[masterrigger1 2]

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Don is a Master Rigger.

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I believe he got his ticket many years ago and seems to not know the regulations very well and no longer uses his certificate

***I aslo have asked for an interpertation and got a written one and a verbal one both reflecting what I have stated above.

From an Inspector, same as the one I have. The fact that we have 2 opposite interpretations from 2 Inspectors tells me that the FAR's are not very clear and can be interpreted differently.

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The difference here is that my inspector is a "grassroots" rigger that uses his ticket every week as he is active in rigging weekly.


***As for AC-105-2C, it defines alterations as changes to the FAA approved configuration. It also lists examples of approved parachutes as parachutes manufactured under a type certificate, under TSO C23, and military parachutes. That excludes mains, by definition.

That is your definition which I believe to be very wrong.
I hope this thread dies in the near future. I have spent too much time on this thread!
I guess we will continue the wait!

Blue Ones,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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[masterrigger1 2]

I agree with everything you said except the item below

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However, the manufacturer is also allowed to replace lines. I would argue that if the manufacturer sells me a line set he is authorizing me to finish the repair by installing the lineset. That is what makes the major repair legal when done by a senior rigger or whoever. A master rigger would have the authority to create a line or lineset from scratch and install it without the manufacturers approval.

[riggerrob 643]

Any employee of the manufacturer can do major repairs while working for the facility, with or without a riggers certificate. ( go figure!)

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

... provided that all repairs pass a TSO inspector.

The TSO process is primarily a quality control process that involves promising the FAA that you will follow a process, following that process, then creating a paper trail that proves that you followed that process. It starts with certified materials cut to approved patterns, sewn, then inspected, then sewn some more and inspected some more, etc.
The TSO process is an auditing process related to ISO 9000 or financial auditing.
The majority of production line sewing is done by little Latino ladies who have never packed a reserve parachute - much less earned a rigger's certificate - however, they can sew straight lines all day long, far straighter and far quicker than the next hundred licensed riggers and for a fraction of the pay that riggers demand. I have the utmost respect for Lita, Consuello, etc. as they are far better seamstresses than I will ever be.
As long as their sewing passes a TSO inspector, who cares who cut the lines, operated the sewing machine, set the grommets, etc.