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QuoteI agree with what you said, but I would like to know why RW has not moved from b to d. All these changes are definitly not minor changes even if they been done one by one (which is not the truth). Vector II became III in a split and not year after year after several evolutions.
$$$$$$$$$$$$$
(is my guess)
QuoteQuoteI agree with what you said, but I would like to know why RW has not moved from b to d. All these changes are definitly not minor changes even if they been done one by one (which is not the truth). Vector II became III in a split and not year after year after several evolutions.
$$$$$$$$$$$$$
(is my guess)
Because he can.
My idea of a fair fight is clubbing baby seals
I just love it when the FAA shows up and says "we are here to help you" before they start to go through your records and get the prob out.
Just wished they worked better control on the TSA inspectors....
Just wished they worked better control on the TSA inspectors....
Kenneth Potter
FAA Senior Parachute Rigger
Tactical Delivery Instructor (Jeddah, KSA)
FFL Gunsmith
FAA Senior Parachute Rigger
Tactical Delivery Instructor (Jeddah, KSA)
FFL Gunsmith
QuoteI just love it when the FAA shows up and says "we are here to help you" before they start to go through your records and get the prob out.
Just wished they worked better control on the TSA inspectors....
The FAA doesn't have any control of the TSA inspectors. The work for USA Dept. of Homeland Security.
My idea of a fair fight is clubbing baby seals
JerryBaumchen 1,467
Hi Rob,
You keep doing posts like this one and I'll begin to think you know what you are talking about.
What is it you do?
hee
hee
However, I see nothing that connects any relocation with additional testing. An inspection of the facilities; yes. There is nothing in any FAA document relating to that that I know of (but I do not know of all FAA documens, for sure).
A number of TSO-holders in the NW have relocated many times with no retesting. ParaPhernalia has relocated maybe 4 times, maybe more since Classen first started it up; were you with them during any relocation? Just asking, not being negative.
Jerry
You keep doing posts like this one and I'll begin to think you know what you are talking about.
What is it you do?
hee
hee
However, I see nothing that connects any relocation with additional testing. An inspection of the facilities; yes. There is nothing in any FAA document relating to that that I know of (but I do not know of all FAA documens, for sure).
A number of TSO-holders in the NW have relocated many times with no retesting. ParaPhernalia has relocated maybe 4 times, maybe more since Classen first started it up; were you with them during any relocation? Just asking, not being negative.
Jerry
QuoteHowever, I see nothing that connects any relocation with additional testing.
I think it is a carry over form when TSO’s were issued to an address that was also a loft. They were issued to a specific address. If you changed addresses you had to reapply.
I know when ParaInnovators moved from 1st. st. in Perris to D st. there were all kinds of problem with both the TSO’s and the certified loft.
It was a long time ago and there are a lot of dead brain cells since then so I could be way off.
My idea of a fair fight is clubbing baby seals
riggerrob 643
Sorry Jerry,
But I was not working for Para-Phernalia during one of their many moves.
I was working in Rigging Innovations' California factory when they opened a new production line in Arizona. Initally, the Arizona production lin only built small components (i.e. pilot chutes) under sub-contract to the TSO-holding factory in California, so the FAA did not make much fuss. I was not directly involved with the factory in Arizona.
I suspect that one of the problems with a move is that you might end up with a different FAA Inspector reviewing all your data and asking embarrassing questions. The new inspector might not be willing to accept: "We have been building them that way for 20 years and never had a fatality related to that component." A new FAA Inspector could always insist on you repeating part of the drop test program to provide him with hard numbers that he can use to cover his butt.
Just ask Ray Ferrel about the hassles the FAA has given him over trying to move the Reflex production line from Elsinore to Davis!
Hee!
Hee!
But the last time we discussed the issue, Ray was not in a laughing mood.
But I was not working for Para-Phernalia during one of their many moves.
I was working in Rigging Innovations' California factory when they opened a new production line in Arizona. Initally, the Arizona production lin only built small components (i.e. pilot chutes) under sub-contract to the TSO-holding factory in California, so the FAA did not make much fuss. I was not directly involved with the factory in Arizona.
I suspect that one of the problems with a move is that you might end up with a different FAA Inspector reviewing all your data and asking embarrassing questions. The new inspector might not be willing to accept: "We have been building them that way for 20 years and never had a fatality related to that component." A new FAA Inspector could always insist on you repeating part of the drop test program to provide him with hard numbers that he can use to cover his butt.
Just ask Ray Ferrel about the hassles the FAA has given him over trying to move the Reflex production line from Elsinore to Davis!
Hee!
Hee!
But the last time we discussed the issue, Ray was not in a laughing mood.
JerryBaumchen 1,467
Hi Rob,
Not to keep beating this thing but . . . .
1. I do not work for the FAA and cannot interpret their regs; they are the only ones with that authority.
2. I've relocated a number of times.
The facility inspection (in my experience) is done by someone from the MIDO, not the ACO. I've always consider this facility inspection nonsense. Here, you've built a parachute (complete or component), tested it, and the ACO has determined that your QC manual and Test Report are acceptable. Now along comes some guy from the MIDO who wants to look over your facility to 'see if you can make a parachute there.' That's nuts in my book, you just did it.
One thing about an FAR, it ties the builder's hands and it ties the FAA's hands. They do not have any authority to just make someone test. They need a very sustantiated reason. Now, given that, if they turn their General Counsel on you, you might want to think about whatever it is they are asking.
The way I 'heard' it Ray was trying to do too much of a change at one time. Or maybe someone had it in for him. I do not know the details.
I still do not see anything in the TSO FAR's about any testing being req'd if a facility is moved.
That's my story and I'm sticking with it. That is unless I'm wrong.![[:/]](/uploads/emoticons/dry.png "[:/]")
Jerry
PS) I also donate to my Congressman and both Senators every election. hee hee
Not to keep beating this thing but . . . .
1. I do not work for the FAA and cannot interpret their regs; they are the only ones with that authority.
2. I've relocated a number of times.
The facility inspection (in my experience) is done by someone from the MIDO, not the ACO. I've always consider this facility inspection nonsense. Here, you've built a parachute (complete or component), tested it, and the ACO has determined that your QC manual and Test Report are acceptable. Now along comes some guy from the MIDO who wants to look over your facility to 'see if you can make a parachute there.' That's nuts in my book, you just did it.
One thing about an FAR, it ties the builder's hands and it ties the FAA's hands. They do not have any authority to just make someone test. They need a very sustantiated reason. Now, given that, if they turn their General Counsel on you, you might want to think about whatever it is they are asking.
The way I 'heard' it Ray was trying to do too much of a change at one time. Or maybe someone had it in for him. I do not know the details.
I still do not see anything in the TSO FAR's about any testing being req'd if a facility is moved.
That's my story and I'm sticking with it. That is unless I'm wrong.
Jerry
PS) I also donate to my Congressman and both Senators every election. hee hee
Jerry,
This is a direct quote from a TSO authorization issued to a well-known gear manufacture in January 2000.
“This authorization is not transferable to another person or location and is effective until surrendered, withdrawn, or otherwise terminated by the Administrator.”
This is a direct quote from a TSO authorization issued to a well-known gear manufacture in January 2000.
“This authorization is not transferable to another person or location and is effective until surrendered, withdrawn, or otherwise terminated by the Administrator.”
My idea of a fair fight is clubbing baby seals
JerryBaumchen 1,467
Hi Sparky,
We are getting into definitions here; but that is OK.
I, 100% know, it is not transferrable; to another person or to another location. The location refers to transferring to another location.
This is sort of like the Minor Change; everything is done as a Minor Change and never as a Major Change. Ergo, one never 'transfers' a TSO-authorization. You can sell the company that holds the TSO, you can relocate the company that holds the TSO; these things are available to the TSO holder.
VSE's Infinity was originally TSO'd by (company owner) Larry Chernis (sp?), then Kelly bought it (the company), then he relocated it (the company) to Puyallup, and he is currently in the process of relocating it (the company) to Bend, OR. I just talked to him yesterday about this very issue.
The real trick is never mention the word 'transfer' to an FAA-type; they get all excited and start spouting regs that even they know little of.
We should never live in fear of the FAA. From my experience, their thing is all about paperwork and is it in order, is it consistent, etc.
Also (I got thinking about this last night), if they were to come in and demand that I run some testing, I would ask that they put the request in writing. I would then present them with an estimate of what the testing will cost and inform them that I will be submitting a claim to them for all costs associated with this testing. I will bet you $5.00 to a stale doughnut that they would retract their demand.
Last fall I got a letter from my ACO informing me that I had to submit any Minor Change(s) within six months of the change being effective. I called the FAA-type up and said that I did not see anything in any FAR that gave them the authority to impose this req'ment on me or anyone else. She agreed that the FAA lacks such authority and said that they would like these things within a six-month period. I was very courteous but firm with her.
Lastly, these are my thoughts based upon my personal experience with the FAA as regards TSO's (26 yrs of dealing with them) and my 30 yrs of employment by the federal gov't. Others may disagree with me; it is OK with me if someone does.
I hope this helps you understand this; I know it can be very confusing. Give me a call if you would like to discuss it some more or remember it for Reno (it was Grey Goose, right?),
Jerry
We are getting into definitions here; but that is OK.
I, 100% know, it is not transferrable; to another person or to another location. The location refers to transferring to another location.
This is sort of like the Minor Change; everything is done as a Minor Change and never as a Major Change. Ergo, one never 'transfers' a TSO-authorization. You can sell the company that holds the TSO, you can relocate the company that holds the TSO; these things are available to the TSO holder.
VSE's Infinity was originally TSO'd by (company owner) Larry Chernis (sp?), then Kelly bought it (the company), then he relocated it (the company) to Puyallup, and he is currently in the process of relocating it (the company) to Bend, OR. I just talked to him yesterday about this very issue.
The real trick is never mention the word 'transfer' to an FAA-type; they get all excited and start spouting regs that even they know little of.
We should never live in fear of the FAA. From my experience, their thing is all about paperwork and is it in order, is it consistent, etc.
Also (I got thinking about this last night), if they were to come in and demand that I run some testing, I would ask that they put the request in writing. I would then present them with an estimate of what the testing will cost and inform them that I will be submitting a claim to them for all costs associated with this testing. I will bet you $5.00 to a stale doughnut that they would retract their demand.
Last fall I got a letter from my ACO informing me that I had to submit any Minor Change(s) within six months of the change being effective. I called the FAA-type up and said that I did not see anything in any FAR that gave them the authority to impose this req'ment on me or anyone else. She agreed that the FAA lacks such authority and said that they would like these things within a six-month period. I was very courteous but firm with her.
Lastly, these are my thoughts based upon my personal experience with the FAA as regards TSO's (26 yrs of dealing with them) and my 30 yrs of employment by the federal gov't. Others may disagree with me; it is OK with me if someone does.
I hope this helps you understand this; I know it can be very confusing. Give me a call if you would like to discuss it some more or remember it for Reno (it was Grey Goose, right?),
Jerry
Jerry,
If I understand you correctly, it boils down to your choice of the “right” word when advising the FAA of your intentions.
In this case you are not moving or “transferring” but simply relocating your production facilities.
Thanks for the information. As is often the case there is a simple solution to a simple problem. It is just a matter of finding it.
If I understand you correctly, it boils down to your choice of the “right” word when advising the FAA of your intentions.
In this case you are not moving or “transferring” but simply relocating your production facilities.
Thanks for the information. As is often the case there is a simple solution to a simple problem. It is just a matter of finding it.
My idea of a fair fight is clubbing baby seals
QuoteHi Rob,
Not to keep beating this thing but . . . .
1. I do not work for the FAA and cannot interpret their regs; they are the only ones with that authority.
2. I've relocated a number of times.
The facility inspection (in my experience) is done by someone from the MIDO, not the ACO. I've always consider this facility inspection nonsense. Here, you've built a parachute (complete or component), tested it, and the ACO has determined that your QC manual and Test Report are acceptable. Now along comes some guy from the MIDO who wants to look over your facility to 'see if you can make a parachute there.' That's nuts in my book, you just did it.
One thing about an FAR, it ties the builder's hands and it ties the FAA's hands. They do not have any authority to just make someone test. They need a very sustantiated reason. Now, given that, if they turn their General Counsel on you, you might want to think about whatever it is they are asking.
The way I 'heard' it Ray was trying to do too much of a change at one time. Or maybe someone had it in for him. I do not know the details.
I still do not see anything in the TSO FAR's about any testing being req'd if a facility is moved.
That's my story and I'm sticking with it. That is unless I'm wrong.
Jerry
Just as an aside, MIDO conducts an audit every two years of each "approved" facility, be it, aircraft or parachute. ACEP audits are a matter of routine. They cover all manner of manufacturing, Tool and gauge control, raw material procurement, traceability, constistency of what is built VS what is written, etc, etc, the list is long.
I found out very early on during the process, if you give the inspector what he's looking for, good or bad you can go on business as usual (if wrong, you have a time frame to correct mistakes). These guys are auditors pure and simple! If you are honest with them they will work with you. If,however you are not so forthcoming They will sense it and make life miserable. Their job is to police the TSO standards. They also know that nothing is perfect and some adjustments need to be made at various levels. Bottom line is: If you are honest with them they will be fair to you!!
MIDO are NOT THE BAD GUYS!! They are simply carrying out their mandate. They don't give a flying fuck about parachute equipment as long as it meets the REQUIRED standards, plain and simple. If you have somthing to hide be afraid very afraid!!
I have personally "been there and done that". Several times!
Hope this brings some clarity to the discussion.
Mick.
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468
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