That is their perogative.
Most manufacturers wouldn't allow this type of mod to be done outside their factories, when I was in the business I never allowed it. Under our TSO drawings and QC manual proceedures, the outer skin of the reserve container (as well as everything else in the reserve system) is covered under the terms and conditions of that document. Most if not all (harness/ container) manufacturers TSO drawings should encompass the outer skin of the reserve container. It would be rather difficult to certify a container without that particular item being covered.
That being said: Each and every manufacturer has the perogative to allow or disallow this type of modification.
Glad to hear you have the ability and the blessing to do it from the manufacturer. If there is a need for it then you are fullfilling that need.
Mick.
Most manufacturers wouldn't allow this type of mod to be done outside their factories, when I was in the business I never allowed it. Under our TSO drawings and QC manual proceedures, the outer skin of the reserve container (as well as everything else in the reserve system) is covered under the terms and conditions of that document. Most if not all (harness/ container) manufacturers TSO drawings should encompass the outer skin of the reserve container. It would be rather difficult to certify a container without that particular item being covered.
That being said: Each and every manufacturer has the perogative to allow or disallow this type of modification.
Glad to hear you have the ability and the blessing to do it from the manufacturer. If there is a need for it then you are fullfilling that need.
Mick.
The need is really not that great. I've only done it a few times. It is a technique I learned from one of the major manufactures that I have worked closely with over the years.
I'd like to address something you said. You mentioned that every part of the system, should be covered under the TSO and QC manuals and therefore the type of repair I performed would, in your opinion, void the TSO. Would that include changing out the closing loop? After all, wouldn't loop length and material type be part of the TSO testing paramiters? I realize that I am taking it a bit far but where exactly is the line drawn and who gets to cross it? Imagine having to always buy your closing loops from the manufacture. Talk about a pain in the ass.
If the above statement where true as Sandy Ried of RI has said, then when would a properly certified rigger be allowed to perform any kind of repair much less a major one? If I understand your point the answer would be never because you as the manufacture could not varify the QC of the repair.
Opinions may vary but the way I read the regs, I am able to do quite alot to a rig with out first seeking the manufactures approval providing I do not alter the rigs function or design.
If however, if I do intend to alter the rigs design or funtion, only then I must then seek approval from the manufacture. If I fail to receive manufacture authorization, then my next step (were I so inclined) would be to go over the manufactures head to the FAA as Ray Ferrall did regarding the RSL on RWS systems.
A move, I might add, I would be very hesitant to make.
All of the above is with in the perveiw of my master riggers certificate. Seeking the manufactures approval for a major repair is not required. The FAA has already granted me all the approval I need but manufactures like to imply other wise.
Consider this. What if an owner of an aircraft wanted to paint his or her airplane a different color and in doing so, the tail section or any other section needed to be removed. Would doing that void the aircraft's TSO? By my thinking, the answer would be no if the work was performed by some one qualified and properly rated to do the work.
I understand the reason most manufactures discourage riggers in the field from performing these types of repairs. The reason is simply that most riggers do not possess all of the elements necessary to do the work correctly.
Kevin
QuoteQuoteYes, overlays will make flaps stiffer.
If overlays change the geometry, then that is sloppy workmanship.Quote
Don't forget Rob, that overlays will void the TSO unless the manufacturer provides a letter authorizing the procedure, accompanied by drawings etc. Like you said: send it back to the manufacturer it's the best way.
Mick,
The last time I checked the FAA issues the TSO.
They(FAA) can and will approve alterations, modifications and major repairs if you follow the appropriate paper trail.
While it may not be wise to go against the gain of the manufacturer: you do not need their appoval to do it IF you have the approval from the local FSDO.
I have received several approvals following their guidelines in the past.It is a simple process and very legal.
MELSkyworks Parachute Service, LLC
www.Skyworksparachuteservice.com
I'd like to address something you said. You mentioned that every part of the system, should be covered under the TSO and QC manuals and therefore the type of repair I performed would, in your opinion, void the TSO. Would that include changing out the closing loop? After all, wouldn't loop length and material type be part of the TSO testing paramiters? I realize that I am taking it a bit far but where exactly is the line drawn and who gets to cross it?
In theory all parts should be from the manufacturer but in reality they are not. Example, replacing a rudder cable on a small A/C. You could go to the factory and buy the part (which they would have to make for you as they generally wouldn't keep a box of pre made ones around) or you could (as most A & P's do) make it yourself following the manufacturers instructions using approved materials, tools and procedurers. Just like a closing loop it's a matter of practicality.
If one is an apropriatly rated repairman, he/ she could elect to re-skin a damaged part of the fuselage or send it to the manufacturers repair facility for the work to be performed.
There has always existed a "legal grey area" for this type of work and no doubt always will.
As I stated before if you have the factory's aproval more power to you, if it were me in your shoes I'd get it in writing.
Mick.
In theory all parts should be from the manufacturer but in reality they are not. Example, replacing a rudder cable on a small A/C. You could go to the factory and buy the part (which they would have to make for you as they generally wouldn't keep a box of pre made ones around) or you could (as most A & P's do) make it yourself following the manufacturers instructions using approved materials, tools and procedurers. Just like a closing loop it's a matter of practicality.
If one is an apropriatly rated repairman, he/ she could elect to re-skin a damaged part of the fuselage or send it to the manufacturers repair facility for the work to be performed.
There has always existed a "legal grey area" for this type of work and no doubt always will.
As I stated before if you have the factory's aproval more power to you, if it were me in your shoes I'd get it in writing.
Mick.
QuoteAs I stated before if you have the factory's aproval more power to you, if it were me in your shoes I'd get it in writing.
I would say if he doesn't have it in writing, in detail, he doesn't have it. Remember this is the FAA you are dealing with.
Sparky
My idea of a fair fight is clubbing baby seals
This could prove to be interesting in the future.
Sparky
Sparky
My idea of a fair fight is clubbing baby seals
Sparky,
You are right. I got to thinking about it.
If you are doing a field modification or major repair to a certificated componet, you have to go through the FSDO anyway.
You have to have written permission to do the work!
MEL
You are right. I got to thinking about it.
If you are doing a field modification or major repair to a certificated componet, you have to go through the FSDO anyway.
You have to have written permission to do the work!
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com
www.Skyworksparachuteservice.com
QuoteSparky,
You are right. I got to thinking about it.
If you are doing a field modification or major repair to a certificated componet, you have to go through the FSDO anyway.
You have to have written permission to do the work!
MEL
Sorry Mel but your dead wrong on this one. This is not a gray area. It is clearly spelled out. Master riggers may make major repairs. Senior riggers may not make major repairs unless supervised by a master rigger.
No where does it say that I must get approval for a repair once I have my masters ticket. Alterations yes but not repairs. In fact, I'll bet if you called the FSDO about a repair, they would not have the slightest idea what the hell you where talking about. They might know something about aircraft but trust me, they don't know dick about parachutes except who may work on them and when they need to be repacked. Beyond that, they are lost. The FSDO guy will say something like. "Are you a master rigger?" You'll say "yes" then he'll say "ummm lets see.... well I guess you can do the work then" End of story. He doesn't know you or your skills. He only has a very thick book full of regs to go by and frankly, the conversation was a complete waist of not only your time, but his as well. Try reaching him after three in the after noon or on a weekend. Good luck.
Why after all would the FAA grant some one the capacity to perform major repairs only to make them check in every time they did one? Would this include something as basic as installing a patch larger than 8" and incorporating it into a seem. After all that is one definition of a major repair is it not? Hell, I do that one every day of the week and twice in sunday. Do you mean to tell me that I have been in violation of the regs all this time? Not bloody likely.
Am I to believe that there are major repairs and then there are "MAJOR" repairs? I don't know about you but I fail to draw a distinction. The common denominator is the word repair. Either it's major or it isn't. It's either a repair or is an alteration. The two are not the same.
A master rigger is only required to indicate on the packing record and his or her log book that they performed a repair. Needing to call the FSFO or the manufacture before doing a major repair is not only impractical but is simply not true. I think your confusing alterations with repairs.
An overlay of the reserve flaps is not a repair, major or minor. It is an alteration. Nothing is being repaired, it is being altered.
Sparky
Sparky
My idea of a fair fight is clubbing baby seals
QuoteAn overlay of the reserve flaps is not a repair, major or minor. It is an alteration. Nothing is being repaired, it is being altered.
Sparky
That was the point I was trying to make, I guess I could have just come right out and said it. Although some may consider the second skin "applique"(sp) IE: cosmetics like stripes, piping etc and not an "alteration". Uh oh it's getting grey in here again.
Mick.
That is not what the manufacture told me when I called to get their opinion on the matter before doing the job. They viewed it simply as a major repair because, the method I use does not change any of the flaps configuration or operation. Everything went back together exactly as it came apart.
They did tell me however that there where very few riggers in the world that they would feel comfortable with doing that sort of work out side of the factory. However, because they know me, know that I have the skills, the ratings, the machines, and the properly certified materials, and that I was not changing the function of the rig in any significant way they gave me the go ahead. I suppose that there will be those of you who disagree, but the manufacture did not.
That was 5 years ago and the rig is still in the air. It has long since left my care and is now being cared for by other riggers who have called the manufacture on their own to verify that the repair was authorized Each has recieved the same answer. YES IT WAS
That is their perogative.
Most manufacturers wouldn't allow this type of mod to be done outside their factories, when I was in the business I never allowed it. Under our TSO drawings and QC manual proceedures, the outer skin of the reserve container (as well as everything else in the reserve system) is covered under the terms and conditions of that document. Most if not all (harness/ container) manufacturers TSO drawings should encompass the outer skin of the reserve container. It would be rather difficult to certify a container without that particular item being covered.
That being said: Each and every manufacturer has the perogative to allow or disallow this type of modification.
Glad to hear you have the ability and the blessing to do it from the manufacturer. If there is a need for it then you are fullfilling that need.
Mick.