deadwood 0
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I do rigging most days, parachuting or otherwise and am current. It seems to me that with an 180 day pack cycle riggers will be doing half as many inspections and packing of reserves which could add up to nearly half as many days of rigging to be current as a rigger. Many riggers I know have another job. Go to even the busiest dz's and you might find 'a' full time rigger working at a loft. Even with 120 day cycle parachute rigging as a full time job still does'nt produce very many full time jobs for a parachute rigger. How do riggers stay within the 90 days a year currency requirement now? Later?
I am not really replying to any particular post here. So, while the website might say I am replying to deadwood's post, I don't intend it to be interpreted that way.
I want to mention some aspects of the regulations that haven't been touched on so far, and though they might be considered small things by some, I think they should be given some time and attention.
The currency requirement as set forth in FAR 65.129.f.1 says "Performed duties under his certificate for at least 90 days within the preceding 12 months".
This regulation specifically mentions "duties" as opposed to "privileges".
FAR 65.121 "Certificates: Privileges" does not define duties. As the title says, it defines privileges.
(Definition, "privileges" are things I am allowed to do; "duties" are things I shall or must do.)
I don't know of any section that defines duties specifically, except possibly FAR 65.131 which says "Each certificated parachute rigger shall keep a record of the packing, maintenance, and alteration of parachutes performed or supervised by him. He shall keep in that record, with respect to each parachute worked on, a statement of...".
So, it may be that the only "duty" we have is to log our work, and for the purpose of compliance with FAR 65.129.f.1, it may be that only logged work contributes to currency.
If the only things we are logging are reserve repacks and maintenance on the gear involved, it might be than anyone who doesn't log work on 90 days of the last year might be considered by the FAA to be non-current. Logging 90 repacks on 60 days, for instance, also might not meet the currency requirement as put forth in FAR 65.129.f.1, because it doesn't actually mention how much work is required, but only mentions that you need to have "performed duties" on 90 days of the preceding 12 months.
Now, I don't like the implications of this train of thought any more than any other rigger does. But if any rigger certificate action went in front of the FAA review board or the NTSB, I believe they could very easily interpret the regulations in the manner that I have here. It is well documented that people (mostly pilots, I'll grant you) have had certificates revoked for smaller details than this. All it takes is a little reading of "AOPA Pilot" magazine to find horror stories about what happened to pilots and other certificate holders for seemingly tiny misinterpretations of the rules.
FAR 65.129.f.1 has some other implications that haven't been discussed.
For instance, riggerrob pointed out that "If you want to be picky .. the American Federal Air Regulations require main parachutes to be packed by licensed riggers or "the next person who intends to jump it." Actually, there's a little more to it than that. It is also allowed that a main can be packed by a non-certified individual who was *supervised* by someone with a certificate. But 65.129.f.1 also says that supervision must be logged. There are a lot of paid packers out there who are not certificated riggers. Many DZs suggest that nearby riggers are supervising these people, but according to 65.129.f.1, if it isn't logged, it isn't supervision.
The rewrite of the parachuting regs a few years ago greatly expanded the list of people who might be held responsible when parachuting regulations are broken. So, for example, while many DZOs choose to take the attitude that the paid packers in the packing area are independent of their control, that might not fly if the FAA gets involved.
I understand that all this presupposes that the FAA chooses to take some action, and that doesn't often seem likely. But I worry that a great deal of what we consider normal could be "actionable" if anyone in the FAA decided to start taking shots at us.
I want to mention some aspects of the regulations that haven't been touched on so far, and though they might be considered small things by some, I think they should be given some time and attention.
The currency requirement as set forth in FAR 65.129.f.1 says "Performed duties under his certificate for at least 90 days within the preceding 12 months".
This regulation specifically mentions "duties" as opposed to "privileges".
FAR 65.121 "Certificates: Privileges" does not define duties. As the title says, it defines privileges.
(Definition, "privileges" are things I am allowed to do; "duties" are things I shall or must do.)
I don't know of any section that defines duties specifically, except possibly FAR 65.131 which says "Each certificated parachute rigger shall keep a record of the packing, maintenance, and alteration of parachutes performed or supervised by him. He shall keep in that record, with respect to each parachute worked on, a statement of...".
So, it may be that the only "duty" we have is to log our work, and for the purpose of compliance with FAR 65.129.f.1, it may be that only logged work contributes to currency.
If the only things we are logging are reserve repacks and maintenance on the gear involved, it might be than anyone who doesn't log work on 90 days of the last year might be considered by the FAA to be non-current. Logging 90 repacks on 60 days, for instance, also might not meet the currency requirement as put forth in FAR 65.129.f.1, because it doesn't actually mention how much work is required, but only mentions that you need to have "performed duties" on 90 days of the preceding 12 months.
Now, I don't like the implications of this train of thought any more than any other rigger does. But if any rigger certificate action went in front of the FAA review board or the NTSB, I believe they could very easily interpret the regulations in the manner that I have here. It is well documented that people (mostly pilots, I'll grant you) have had certificates revoked for smaller details than this. All it takes is a little reading of "AOPA Pilot" magazine to find horror stories about what happened to pilots and other certificate holders for seemingly tiny misinterpretations of the rules.
FAR 65.129.f.1 has some other implications that haven't been discussed.
For instance, riggerrob pointed out that "If you want to be picky .. the American Federal Air Regulations require main parachutes to be packed by licensed riggers or "the next person who intends to jump it." Actually, there's a little more to it than that. It is also allowed that a main can be packed by a non-certified individual who was *supervised* by someone with a certificate. But 65.129.f.1 also says that supervision must be logged. There are a lot of paid packers out there who are not certificated riggers. Many DZs suggest that nearby riggers are supervising these people, but according to 65.129.f.1, if it isn't logged, it isn't supervision.
The rewrite of the parachuting regs a few years ago greatly expanded the list of people who might be held responsible when parachuting regulations are broken. So, for example, while many DZOs choose to take the attitude that the paid packers in the packing area are independent of their control, that might not fly if the FAA gets involved.
I understand that all this presupposes that the FAA chooses to take some action, and that doesn't often seem likely. But I worry that a great deal of what we consider normal could be "actionable" if anyone in the FAA decided to start taking shots at us.
All you have to do is post once every 90 days in the gear and rigging forum. That counts, right?
riggerrob 643
Riggerrob lipping off ....
If you made "x" number of jumps this year, and packed your own main canopy "x'" number of times, then you did rigging work on "y" number of days.
The only time the FAA will care - how many days you rigged last year, is if your name gets connected to a fatality.
Kind of like ... a long time ago, i was on a cross-country flight (in a Cessna 182) when the pilot realized that he had forgotten to bring his license. Technically that is illegal in Canada, however, he replied "Transport Canada will only ask to see my license if I wreck this airplane, then missing a license will be the least of my worries."
If you made "x" number of jumps this year, and packed your own main canopy "x'" number of times, then you did rigging work on "y" number of days.
The only time the FAA will care - how many days you rigged last year, is if your name gets connected to a fatality.
Kind of like ... a long time ago, i was on a cross-country flight (in a Cessna 182) when the pilot realized that he had forgotten to bring his license. Technically that is illegal in Canada, however, he replied "Transport Canada will only ask to see my license if I wreck this airplane, then missing a license will be the least of my worries."
QuoteRiggerrob lipping off ....
If you made "x" number of jumps this year, and packed your own main canopy "x'" number of times, then you did rigging work on "y" number of days.
The only time the FAA will care - how many days you rigged last year, is if your name gets connected to a fatality.
Kind of like ... a long time ago, i was on a cross-country flight (in a Cessna 182) when the pilot realized that he had forgotten to bring his license. Technically that is illegal in Canada, however, he replied "Transport Canada will only ask to see my license if I wreck this airplane, then missing a license will be the least of my worries."
I have no doubt that what you say is true, or certainly has been true in our experiences to date.
But that doesn't really answer the question of what is actually required to be in compliance with the regulations.
I've tried to get answers to this and other questions like it from the Sacramento FSDO, but they have been essentially unresponsive.
Maybe somebody out there has dealt with a FSDO that is more responsive, and if so, I hope they can ask on our behalf and post the answer. Terry (Councilman24), you seem to be as well connected as anyone, do you and/or PIA have something to say on this question. Can you get the FAA to clarify things any?
JerryBaumchen 1,465
Hi riggerpaul,
QuoteCan you get the FAA to clarify things any?
That will happen when the cows come home, when eskimos start buying ice cream cones, and women will think I am the answer to their prayers.
I think riggerrob has hit the nail on the proverbial head. It will only matter when the 'goodies' hit the moving fan blades.
If you inspect your rig each day prior to beginning jumping, you have performed some of your 'duties' as a rigger. Your reserve container and your harness are certificated and an inspection of them (IMO) is sufficient performance of that duty. I do not think that it has to be a full 100%/open it up inspection, just an inspection that everything looks airworthy.
Just my worth-not-so-much two cents,
JerryBaumchen
riggerrob 643
I've tried to get answers to this and other questions like it from the Sacramento FSDO, but they have been essentially unresponsive.
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
Stop pestering the FAA.
The FAA don't care.
The FAA won't care until there is a fatality.
Pestering the FAA before an accident is like pestering a hibernating bear!
You may not enjoy the answer!
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
Stop pestering the FAA.
The FAA don't care.
The FAA won't care until there is a fatality.
Pestering the FAA before an accident is like pestering a hibernating bear!
You may not enjoy the answer!
It will be whatever the FAA wants it to be to suit their case. They will not define it until they need to.
Deadwood
Skydive New Mexico Motorcycle Club, Touring Division
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