How do part-time riggers document currency?

[GLIDEANGLE 1]

Y’all:

How I got into this …. Last weekend I was enjoying the social atmosphere at the DZ after a pretty sunset jump. I saw three riggers gathered around a rig. One rigger was head down in this rig with needle, thread, and a sailmaker’s palm. I made the mistake of approaching this group of friends and acquaintances to find out what fun thing was being done to the rig.

Before I knew it, the three of them were trying to convince me to learn to rig and to pursue the rating. One rigger commented: “You have the right personality for it!” (I don’t know if I should consider that as a compliment or not!) Heck, one of the riggers had previously said that I had “the right personality for CReW”. (I think that may even be more worrisome than the rigging comment).
As I begin to explore the US regulations regarding rigging, I note the currency requirement of 90 days in the last year. That is a lot of time (one out of every four days). I would be delighted if I got 90 days a year to jump….let alone rig. So, here are my questions:

• How do “part-time” or “I just do reserves for myself and my friends” riggers keep current?
• How do riggers document their 90 days beyond the use of their rigger’s logbook?

There are lots of rigging activities that wouldn’t appear in a logbook (providing advice, supervising the paid main canopy packers, teaching rigging issues to jumpers). Do part-time riggers capture these activities as part of “90 days in the least year”?

I imagine that some folks will consider my concern with documenting currency to be excessive (“Hey, the rating is for life…”). My concerns are that if an injury or death were to occur to jumper using a rig worked on while being un-current, it would open the door widely for a prompt and successful civil liability suit and/or FAA fines (I bet that a bright and motivated US Attorney could easily turn this into a federal criminal charge too.) I would expect that doing rigging while un-current would disable any wavier of liability that the customer might have signed at the DZ.

Yes, I will ask the riggers above these questions, but I look forward to your responses too.

Thanks for your thoughts!

Blue Skies.

The choices we make have consequences, for us & for others!

[tdog 0]

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As I begin to explore the US regulations regarding rigging, I note the currency requirement of 90 days in the last year.

Are you mixing up PACKING ONE RIG in the last 90 days, or working 90 days out of 365 in the industry??? I think it is the first, but you think it is the second.

Please find your source and quote it, as this is a new one to me...

[mark 107]

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As I begin to explore the US regulations regarding rigging, I note the currency requirement of 90 days in the last year.

Are you mixing up PACKING ONE RIG in the last 90 days, or working 90 days out of 365 in the industry??? I think it is the first, but you think it is the second.

Please find your source and quote it, as this is a new one to me...

Here you go:

FAR 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; or
(f) Exercise the privileges of his certificate and type rating
unless he understands the current manufacturer's instructions for the
operation involved and has--
(1) Performed duties under his certificate for at least 90 days
within the preceding 12 months; or
(2) Shown the Administrator that he is able to perform those duties.

Mark

[councilman24 37]

In case you couldn't pick it out....

(1) Performed duties under his certificate for at least 90 days
within the preceding 12 months; or
(2) Shown the Administrator that he is able to perform those duties.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[councilman24 37]

I don't know of any rigger ever being asked to document the currency requirement. It could happen. I do know that there have been a few riggers who documented main pack jobs. Any other repairs, assembly of systems, etc. should be documented in a log.

I don't document mains. But between packing my gear, inspecting gear etc. I'm not too worried about it. The regs specifically say you don't have to document mains even though your doing them under your rigger license. It would be a hard thing to prove either way.

It's very rare that a rigger gets sued. Even when they probably should be included in a lawsuit they aren't. One currently ongoing lawsuit alleging that a PC with major damage when packed contributed to the injuries still did not include the rigger in the lawsuit. And most of us don't believe the supposed damage anyway.

If your worried about liability or regulatory enforcement there are a LOT of other things to worry about than currency. It just really isn't a practical issue. I only know of two riggers who have been the object of enforcement actions. One was only a letter of reprimand and one was a single count fine. Both probably deserved it. Neither had anything to do with currency. But those are the ONLY two enforcement actions by the FAA against a rigger that I'm familiar with. Oh I think there was one more that was the subject of a sting operation to prove they were pencil packing. But it took a set up to prove it.

Riggers are not usually covered by DZ waviers unless employees of the DZ. And even then I wouldn't count on it. And I still haven't found any independant rigger who uses a wavier with their customers. I've tried several times. And one of the 2 or 3 lawyers the industry uses to defend lawsuits didn't see much value in a rigger using a wavier.

By some of the books and start studying.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[tdog 0]

Wow.

So, what is 90 days? One minute a day touching skydiving gear? Or an 8 hour day packing? Seems hard to judge.

Also, I know a few very good riggers who have day jobs and work on gear a few days a month. It seems that the majority of riggers are skydivers who rig here and there. Few call it their full time gig. So, it looks like a lot of people are not getting the 90 days.

So the "or" number 2 is what saves them, huh?

[2shay 0]

so if my pack my own resreve and mine only and jump in between is that enough or am I missing somehting here.

don't try your bullshit with me!!!

[DrewEckhardt 0]

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so if my pack my own resreve and mine only and jump in between is that enough or am I missing somehting here.

That may be legal if you jump at least 89 day of the year.

[GLIDEANGLE 1]

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so if my pack my own resreve and mine only and jump in between is that enough or am I missing somehting here.

Let's assume you pack your reserve only every 120 days:

If you use the liberal counting method initially proposed by tdog you would not have done any rigging in the previous 90 days. (This method is NOT consistent with the regulations)

If you use the conservative counting method (consistent with the regulation) you would have three days of rigging in the previous 12 months.

So as I read it: If your rigging was limited to your own rig every 120 days, by neither method of counting would you be current as defined by the reg above.

The choices we make have consequences, for us & for others!

[GLIDEANGLE 1]

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By some of the books and start studying.

Thanks for the complete and helpful reply and your encouragement!

The choices we make have consequences, for us & for others!

[NickDG 23]

One thing to know about most FAA Regulations are they are written to hold up in court instead of holding something up in the air. Say you pack someone's reserve after being un-current under the rule, and something like a low reserve pull does in your customer. In the course of the investigation it is possible the FAA will want to look at your rigger's logbook. But I'm not sure I ever met a rigger dumb enough to hand over a logbook that shows them as un-current.

Also when the local FSDO is investigating an incident involving a rigger the first person they usually contact is the area's Designated Rigger Examiner. If the DRE says, "Oh yeah, I know Ronny Rigger and he's all right," that's about as far as it will go. The worst thing is when the DRE has to say they never heard of you. This could be the case if you are new to an area or didn't take your rigger's test through that particular DRE. If that's the case seek them out and introduce yourself making it a point to smoosh them a little . . .

NickD BASE 194

[peregrinerose 0]

Keep in mind rigging isn't just doing a reserve repack. I do repacks for myself, my husband, and a few friends, that's it. Definitely not 90 repacks a year. However, I hang out at Dave Dewolf's loft as frequently as I can, work as a packer at the DZ every weekend, read everything I can get my hands on from a rigging standpoint, pick other riggers' brains about things that I don't do on a regular basis, etc... all of that would go under currency as well. I probably devote at least a little time every day to reading and learning and keeping up to date on rigging information.

I think as spelled out, the currency requirements are rediculous. There should be a required 'continuing education' type program so that there is some continuity between riggers, and all riggers are kept up to date on information. I'm required as an eye doc to have so many hours of continuing ed a year, rigging should be no different.

Do or do not, there is no try -Yoda

[klingeme 1]

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so if my pack my own resreve and mine only and jump in between is that enough or am I missing somehting here.

Let's assume you pack your reserve only every 120 days:

If you use the liberal counting method initially proposed by tdog you would not have done any rigging in the previous 90 days. (This method is NOT consistent with the regulations)

If you use the conservative counting method (consistent with the regulation) you would have three days of rigging in the previous 12 months.

So as I read it: If your rigging was limited to your own rig every 120 days, by neither method of counting would you be current as defined by the reg above.

Not really, If you jump and repack yout main you are doing "rigging work", Change your closing loop, Rigging work, change the rubber bands on your main bag, rigging work, do a gear check for someone at the dropzone, rigging work.

[UDSkyJunkie 0]

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So, what is 90 days? One minute a day touching skydiving gear? Or an 8 hour day packing? Seems hard to judge.

Also, I know a few very good riggers who have day jobs and work on gear a few days a month. It seems that the majority of riggers are skydivers who rig here and there. Few call it their full time gig. So, it looks like a lot of people are not getting the 90 days.

So the "or" number 2 is what saves them, huh?

No, because "demonstrated to the administrator..." means taking the practical with a DPRE.

What saves us is that
1) since documentation isn't required, it would be virtually impossible to prove a lack of currency. and
2) the FAA has never (to my knowledge) issued clairifcation of what the hell that part of the FARs means.

When I was working on my rating, I asked every rigger I knew, including the DPRE, what the requirement meant, and every one of them said they didn't know and didn't know anyone who knew.

Ambiguous wording leaves itself open to interperetation... rigger "duties" could be packing a main, doing a gear check, any kind of inspection, any kind of minor repair, helping or teaching another person to pack... just about anything.

"Some people follow their dreams, others hunt them down and beat them mercilessly into submission."

[GLIDEANGLE 1]

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What saves us is that
1) since documentation isn't required, it would be virtually impossible to prove a lack of currency. and
2) the FAA has never (to my knowledge) issued clairifcation of what the hell that part of the FARs means.

When I was working on my rating, I asked every rigger I knew, including the DPRE, what the requirement meant, and every one of them said they didn't know and didn't know anyone who knew.

Ambiguous wording leaves itself open to interperetation... rigger "duties" could be packing a main, doing a gear check, any kind of inspection, any kind of minor repair, helping or teaching another person to pack... just about anything.

Thanks.... that makes great sense!

The choices we make have consequences, for us & for others!

[mark 107]

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If you jump and repack your main you are doing "rigging work." Change your closing loop, rigging work. Change the rubber bands on your main bag, rigging work. Do a gear check for someone at the dropzone, rigging work.

Quote

Rigger "duties" could be packing a main, doing a gear check, any kind of inspection, any kind of minor repair, helping or teaching another person to pack... just about anything.

[Edited to clarify my response to Mark Klingemeyer's post. Edits in italics.]

The complete phrase is "duties under his certificate."

Change your own closing loop? Doesn't require a rigger ticket. If it did, owners couldn't do it and it wouldn't be on the USPA A License Proficiency Card.
Change your own rubber bands? Doesn't require a rigger ticket.
So just jumping and repacking your own main is not "rigging work."

Gear check? Doesn't require a rigger ticket.

Pack a main? Packing your own doesn't require a rigger ticket; packing someone else's does.
Inspections and repairs? Yep, that's rigger work.
Helping or teaching another person to pack? Maybe, if the helper or teacher is going to take responsibility for the pack job. Otherwise, doesn't require a rigger ticket.

If people pack for just themselves and a couple friends, they can rationalize the currency requirements. After all, skydivers aren't falling out of the sky because of poor rigging. They're unlikely to be called on it. They're still just rationalizing, though.

Mark

[diablopilot 2]

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The complete phrase is "duties under his certificate."

Change closing loop? Doesn't require a rigger ticket. If it did, owners couldn't do it and it wouldn't be on the USPA A License Proficiency Card.
Change rubber bands? Doesn't require a rigger ticket.
Gear check? Doesn't require a rigger ticket.

On his/her own gear I agree with you, on someone elses.........pack & maintain.

----------------------------------------------
You're not as good as you think you are. Seriously.

[UDSkyJunkie 0]

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The complete phrase is "duties under his certificate."

True, but again it's ambiguous and open to interperetation. Just because you don't NEED a rigger doesn't necessarily mean a task isn't overed as a "duty under his certificate".

Packing your own main... no, doesn't require a rigger ticket, but since packing another's main does and the skills are equal, it could be argued to be "duties under his certificate".

Same thoughts for gear checks... anyone can do a "gear check", but a rigger could perform the same task and call it an "inspection", putting it under the umbrella of his duties.

Rubber bands, loops... well, that's stretching. But then again, since non-riggers aren't allows to pack another's main, it would seem that non-riggers wouldn't be allowed to replace another's closing loop, so maybe that counts too.

Helping/teaching... again, if a non-rigger can't pack another's main, why would they be allowed to help/supervise/teach?

How about being on the dropzone in the presence of a non-rigger packer. You're "supervising" (doesn't have to be direct supervision, you just have to be readily available after all).

Is it rationalizing? To a point I agree it is, although I'd rather call it "applying a liberal interperetation of the regulations" as a CYA statement. But if we were to accept the very conservative intereperetation that you are implying, then VERY few riggers would meet that. It'd prettymuch be loft/manufacturer employees and full-time packers.

"Some people follow their dreams, others hunt them down and beat them mercilessly into submission."

[NickDG 23]

>>So just jumping and repacking your own main is not "rigging work."
Not true.

I've been "writing off" every "fun" jump I make on my taxes for years and a lot of other riggers do it too, as necessary to maintain proficiency as a parachute rigger. It's just like writing off the gas you use to get to work. Currency and proficiency are a "tool" of the rigger's profession. And I love to go to court with some wuffo FAA lawyer who says it isn't.

And when I change out the rubber bands on my own rig I don't magically shed my rigger rating. And I'll bet my rubber bands are installed with more knowledge and care than a non-rigger's are . . .

NickD BASE 194

[riggerrob 643]

Along those lines ... as long as we KEEP THE FATALITY RATE LOW ... the FAA does not want to bother with defining regulations more tightly.

[riggerrob 643]

There should be a required 'continuing education' program

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

Agreed!

Every PIA Symposium includes the option of earning an FAA Continuing Education Certificate.
I have certificates dating from 1993, 1995, 1997, 2001, 2003, 2005 and 2007.

I also have certificates from: FXC, Airtec and Spekon saying that I am "factory approved" to work on their equipment.

Hint: CSPA counts assisting in training new riggers as refresher training.

Bottom line, I would not trust any rigger who had gone more than 4 years since his last training session.

[NickDG 23]

And as a rigger, you can "write off" your expenses of attending PIA too . . . because it furthers you in the profession.

It all depends of what you write down as your "profession."

I always write "professional parachute jumper" and I'm this close to writing off my travel expenses for B.A.S.E. jumps, as I've been paid to do that too . . .

NickD BASE 194

[peregrinerose 0]

This is why I'm going to make every effort to get to the next PIA Symposium... to learn!!

Do or do not, there is no try -Yoda

[councilman24 37]

The next one is in Barcelona in 2008. The next U.S. one is back in Reno in early 2009.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[peregrinerose 0]

The next Reno one I'm planning to hit. Barcelona is not in my financial possibilities.

How's that anchor of yours, anyway, Terry?

Do or do not, there is no try -Yoda