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freefall138

Swift 175 reserve question

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It becomes the riggers responsibilty to note any defects found. In this case, unairworthy, even if it is not packed.



It doesn't make any sense (to me anyway) that the FAA can force you to work on a parachute. I believe you can look at it and simply refuse the work. And how would anyone know?

What if someone was about to show you a parachute that you knew was unairworthy because someone else looked at it already and told you? Do you think you would be required by law to look at it?

(Hello, Terry! Should we put this on "the list" of questions for the FAA?)

Of course all of this is just you and I interpreting the FAR's. How do we know for sure?

Do you know the form I referred to?

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It doesn't make any sense (to me anyway) that the FAA can force you to work on a parachute. I believe you can look at it and simply refuse the work. And how would anyone know?



The FAA cannot make you work on anything. I never said that anyway.
What the FAA does expect you to do is note "any defects" found.

In this case the rigger did not pack it, but did do work on it it in the form of doing research of which he found out that there was an issue.

It is absolutely no different than if you found a acidic round parachute. You have the responsiblity to take it out of service.....and PIA has a procedure spelled out for the riggers.

I have to ask why you would not make the effort to do it anyway?

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Of course all of this is just you and I interpreting the FAR's. How do we know for sure?



Simple.
Call your local FSDO and ask them what to do when you identify an un-airworthy parachute or airframe component.


BS,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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I have to ask why you would not make the effort to do it anyway?



If it were something that I thought another rigger would be willing to work on and make airworthy.

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Call your local FSDO and ask them what to do when you identify an un-airworthy parachute or airframe component.



I agree that could be done, but should we? Or should we get an interpretation from the FAA at DC? We already have too many FAR's that are interpreted differently by the various FSDO's.

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If it were something that I thought another rigger would be willing to work on and make airworthy



Gary,
Agreed!
But we are talking about a canopy that needs new ribs installed...and no one has the patterns need to make them!

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I agree that could be done, but should we? Or should we get an interpretation from the FAA at DC? We already have too many FAR's that are interpreted differently by the various FSDO's.



I think this issue would be pretty much universal in the outcome if you asked a few different FSDOs.


MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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But isn't it a subjective assessment in some cases?

I mean, if the canopy had been packed by 'another' rigger someplace else he must have felt it WAS airworthy.

The manufacturer is one thing, but I wouldn't like a local 'Joe rigger' arbitrarily pulling a canopy out of service permanently because of 'his' interpretation of something that many times is a judgement call.

Red tagging is one thing, a sharpie on the label is another.

I split a rib once at a cross-port on an older canopy, the rigger I took it to for evaluation deemed it 'unairworthy' and cut the lines off without consulting me...I sent it to the mnfgr for a new rib and lines...put another 300 jumps on it. :S











~ If you choke a Smurf, what color does it turn? ~

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But we are talking about a canopy that needs new ribs installed...and no one has the patterns need to make them!



FYI for everyone:

I just received an email from JC Berland, President of Para-Flite. He sent me the original service bulletin, and also said, "We never issued any follow up specifying the removal from service."

Since the SB indicated that it must be returned to the manufacturer, I doubt that any of these canopies that have never been fixed are going to be, since Para-Flite is likely not interested in doing that.

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It becomes the riggers responsibility to note any defects found. In this case, unairworthy, even if it is not packed.

Also the conditions of the specific TSO will spell out damage, wear, and service conditions.

All of the manufacturers do this as far as I know..
I just got one back from PD.

Cheers,
MEL



The requirement is to note on the packing data card any defects found during the inspection. For unairworthy parachutes, the rigger options are to make it airworthy, or to refuse to pack it. Defacing parachutes is not a rigger privilege.

Please give an example of a specific TSO specification of damage, wear, and service conditions. You should cite the TSO approval documents, not secondary documents like owners manuals. For your example, please explain how the manufacturer has disseminated this information to the field.

What is it that "all of the manufacturers do this as far as I know"? Is this a requirement, or not?

Cheers,
Mark

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The requirement is to note on the packing data card any defects found during the inspection.



Mark,
I consider looking for SB's and AD's part of the inspection.

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For unairworthy parachutes, the rigger options are to make it airworthy, or to refuse to pack it. Defacing parachutes is not a rigger privilege.



Can you cite the document(s) that provide that info or guidance?

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Please give an example of a specific TSO specification of damage, wear, and service conditions.



From TSO-C23d...
TSO-C23d 6/1/94
Page 2
(v) Detailed maintenance instructions, including specific guidance on the limits of wear and damage permissible to webbing material that would warrant replacement.
(vi) The quality control inspection and functional test specification to be used to ensure each production article complies with this TSO, as required by part 21, section 21.605(a)(3) and part 21, section 21.143(a)(3).

Cheers,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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The requirement is to note on the packing data card any defects found during the inspection.



Mark,
I consider looking for SB's and AD's part of the inspection.

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For unairworthy parachutes, the rigger options are to make it airworthy, or to refuse to pack it. Defacing parachutes is not a rigger privilege.



Can you cite the document(s) that provide that info or guidance?

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Please give an example of a specific TSO specification of damage, wear, and service conditions.



From TSO-C23d...
TSO-C23d 6/1/94
Page 2
(v) Detailed maintenance instructions, including specific guidance on the limits of wear and damage permissible to webbing material that would warrant replacement.
(vi) The quality control inspection and functional test specification to be used to ensure each production article complies with this TSO, as required by part 21, section 21.605(a)(3) and part 21, section 21.143(a)(3).

Cheers,
MEL



Unresponsive.

I don't see what looking at SB's and AD's has to do with noting defects found on the data card.

I asked you to cite TSO approval documents, you cited the TSO itself.

I asked you to say how a manufacturer communicated the limits to riggers in the field. No response.

Could you look at my previous post, and respond to it, please?

Cheers,
Mark

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Unresponsive.

I don't see what looking at SB's and AD's has to do with noting defects found on the data card.



Mark,
Sorry, But I just do not get what you are saying.
Not complying with a service bulletin is in my world, a defect, therefore I would note that in the log.

MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Unresponsive.

I don't see what looking at SB's and AD's has to do with noting defects found on the data card.



Mark,
Sorry, But I just do not get what you are saying.
Not complying with a service bulletin is in my world, a defect, therefore I would note that in the log.

MEL



Well, we're making progress. But you're still wrong.

You can write whatever you want on your packing data cards. For the rest of us, FAR 65.131(c) requires "notation of defects found" only when making the entry for a parachute that has been packed. No pack, no entry required by FAR 65.131(c).

The data panel on a canopy is not a packing data card. Writing "unairworthy, do not jump" on the data panel is not called for by FAR 65.131(c). It is not packing, it is not a minor repair, it is not a major repair. It may be an alteration, but that's a real stretch, and you'd need FAA or manufacturer approval to make that alteration. It's not your call. And just because you are unable or unwilling to make it airworthy does not give you the right to prevent another rigger or the manufacturer or anyone else the Administrator thinks is competent from doing the work.

Further, contrary to what you claim in a previous post, there are very few published damage, wear & tear, or service conditions. For example, the reserve pilot chute is a TSO'd component for TSO C-23c and C-23d. How many holes, how big, how close together are acceptable? How many patches? How much weave separation in the mesh is ok?

Finally, the photo of a data panel marked "unairworthy" is not by itself evidence of appropriate action for a rigger to take. There are several reasons why PD might mark the canopy that way. For example, if they wanted to donate a canopy to a rigger school but wanted to ensure it would stay a donation and not be resold, they might mark it "unairworthy." You didn't say the circumstances, and I think we have earned the right to be skeptical.

Cheers,
Mark

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Well, we're making progress. But you're still wrong.



Well, that's your opinion and I think you are wrong.

Here's why!

From the Old outdated 149 Parachute Lofts:

149.15 Reports and Records

(b) Each holder of a parachute loft certificate shall report, on a form prescribed by the Administrator, any recurring or serious defect, or other unairworthy conditions, that he finds in a parachute or part thereof.

Yes it is old, but shows the intent.
That has moved I believe to part 43, but will have to find it for you.


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For the rest of us, FAR 65.131(c) requires "notation of defects found" only when making the entry for a parachute that has been packed. No pack, no entry required by FAR 65.131(c).



So you are speaking for everyone else??? How did that happen? I know of at least 10 different riggers that you do not speak for... that is just today alone.

But....I will give you the data card issue...no pack, no data card entry.

YOu do have to log all work performed in your log book though!


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The data panel on a canopy is not a packing data card. Writing "unairworthy, do not jump" on the data panel is not called for by FAR 65.131(c). It is not packing, it is not a minor repair, it is not a major repair. It may be an alteration, but that's a real stretch, and you'd need FAA or manufacturer approval to make that alteration. It's not your call. And just because you are unable or unwilling to make it airworthy does not give you the right to prevent another rigger or the manufacturer or anyone else the Administrator thinks is competent from doing the work.



You are correct, it is not my right but my responsibilty to do it.

Have you ever done a destructive pull test that was positive?

....and then handed the now unairworthy canopy back to the owner?


And as far as the label, the manufacturer usually identifies with defacing the label as voiding it.

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Further, contrary to what you claim in a previous post, there are very few published damage, wear & tear, or service conditions. For example, the reserve pilot chute is a TSO'd component for TSO C-23c and C-23d. How many holes, how big, how close together are acceptable? How many patches? How much weave separation in the mesh is ok?



The old TSO's usually referenced the MIL specs on this. I believe if you will look there you might a few things.

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Finally, the photo of a data panel marked "unairworthy" is not by itself evidence of appropriate action for a rigger to take. There are several reasons why PD might mark the canopy that way. For example, if they wanted to donate a canopy to a rigger school but wanted to ensure it would stay a donation and not be resold, they might mark it "unairworthy." You didn't say the circumstances, and I think we have earned the right to be skeptical.



Again speaking for everyone....???

JFYI, That was a PD160R. Sent to PD because of of what is believe to be a chemical intrusion of sorts. It was brought in by a customer.

Slight dark stain of the center cell topskin in two places.

The UST's on the left were hard like they had super glue in about 10-14 inches of them.
Also in the left stab B-C-D just below the stabs.

You could literally snap the lines into pieces.

PD returned the canopy as you see/saw it.

Feel free to ask them about it if you are still skeptical.

Cheers,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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For the rest of us, FAR 65.131(c) requires "notation of defects found" only when making the entry for a parachute that has been packed. No pack, no entry required by FAR 65.131(c).



So you are speaking for everyone else??? How did that happen? I know of at least 10 different riggers that you do not speak for... that is just today alone.

But....I will give you the data card issue...no pack, no data card entry.



So I guess on this point I am speaking for everyone, including you.

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The data panel on a canopy is not a packing data card. Writing "unairworthy, do not jump" on the data panel is not called for by FAR 65.131(c). It is not packing, it is not a minor repair, it is not a major repair. It may be an alteration, but that's a real stretch, and you'd need FAA or manufacturer approval to make that alteration. It's not your call. And just because you are unable or unwilling to make it airworthy does not give you the right to prevent another rigger or the manufacturer or anyone else the Administrator thinks is competent from doing the work.



You are correct, it is not my right but my responsibiity to do it.



Semantic nonsense.

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Further, contrary to what you claim in a previous post, there are very few published damage, wear & tear, or service conditions. For example, the reserve pilot chute is a TSO'd component for TSO C-23c and C-23d. How many holes, how big, how close together are acceptable? How many patches? How much weave separation in the mesh is ok?



The old TSO's usually referenced the MIL specs on this. I believe if you will look there you might a few things.



I'm not going to do your research for you. You said you believed all manufacturers had standards for damage, wear & tear, an service conditions. You are entitled believe I will find relevent MIL-SPEC references in TSO C-23b, C-23c, or C-23d, or in NAS-804, AS-8015A, or AS-8015B, if only I look hard enough. I won't find any, though, because there aren't any.

In any case, MIL-SPECs refer to the standards for goods that will be incorporated into military products. MIL-SPECs have largely been superseded by PIA-SPECs in the parachute industry. None of these specs address the issue of acceptable wear limits for items that are already in service. Those wear limits must be established by the manufacturers.

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Finally, the photo of a data panel marked "unairworthy" is not by itself evidence of appropriate action for a rigger to take. There are several reasons why PD might mark the canopy that way. For example, if they wanted to donate a canopy to a rigger school but wanted to ensure it would stay a donation and not be resold, they might mark it "unairworthy." You didn't say the circumstances, and I think we have earned the right to be skeptical.



Again speaking for everyone....???



Just speaking for myself and my puppeteers.


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JFYI, That was a PD160R. Sent to PD because of of what is believe to be a chemical intrusion of sorts. It was brought in by a customer.

Slight dark stain of the center cell topskin in two places.

The UST's on the left were hard like they had super glue in about 10-14 inches of them.
Also in the left stab B-C-D just below the stabs.

You could literally snap the lines into pieces.

PD returned the canopy as you see/saw it.



Explanation accepted.

Cheers,
Mark

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From the Glossary of the Parachute Rigger Handbook (I found this on a miscellaneous web page with a search.)

"FAA Form 8330-2 used to report serious defects or other recurring unairworthy conditions of parachutes or aircraft."

I can't find that form on the FAA web site. You might need to get it from an FAA office.

(Thanks to Tom Dolphin for identifying the form.)

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The data panel on a canopy is not a packing data card. Writing "unairworthy, do not jump" on the data panel is not called for by FAR 65.131(c). It is not packing, it is not a minor repair, it is not a major repair. It may be an alteration, but that's a real stretch, and you'd need FAA or manufacturer approval to make that alteration. It's not your call. And just because you are unable or unwilling to make it airworthy does not give you the right to prevent another rigger or the manufacturer or anyone else the Administrator thinks is competent from doing the work.

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You are correct, it is not my right but my responsibiity to do it.

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Semantic nonsense.



No...Common Sense. That reserve has been packed because it had not been removed from service previously. If it had been marked, I do not think it would have been packed.

I bet if you asked the riggers in question should it have been marked, you might just get a "yes" from them.

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Further, contrary to what you claim in a previous post, there are very few published damage, wear & tear, or service conditions. For example, the reserve pilot chute is a TSO'd component for TSO C-23c and C-23d. How many holes, how big, how close together are acceptable? How many patches? How much weave separation in the mesh is ok?

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The old TSO's usually referenced the MIL specs on this. I believe if you will look there you might a few things.

--------------------------------------------------------------------------------


I'm not going to do your research for you. You said you believed all manufacturers had standards for damage, wear & tear, an service conditions. You are entitled believe I will find relevent MIL-SPEC references in TSO C-23b, C-23c, or C-23d, or in NAS-804, AS-8015A, or AS-8015B, if only I look hard enough. I won't find any, though, because there aren't any.

In any case, MIL-SPECs refer to the standards for goods that will be incorporated into military products. MIL-SPECs have largely been superseded by PIA-SPECs in the parachute industry. None of these specs address the issue of acceptable wear limits for items that are already in service. Those wear limits must be established by the manufacturers.




Like I said the earlier TSO's referenced Mil Specs.
I have attached a PDF file for you.

Please note MIL-STD-849. It spells out the inspection process and standards.

Mil specs were not just for fabrics and materials as you stated.

Cheers,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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