180 Day Repack news

[masterrigger1 2]

Terry, What is PIA writing?

I am aware of the stuff that USPA is writing and also the FAA, just not the PIA.

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

The following was transplanted from another thread for reference.

MEL wanted to move the continuing discussion there back to this thread.

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The responsibility lies with the jumper

Paul,
The FAA is now beyond that point that you are trying to make. They now know that they need to write section for this.

Also,
From Part 105: Definitions

Parachute operation means the performance of all activity for the purpose of, or in support of, a parachute jump or a parachute drop. This parachute operation can involve, but is not limited to, the following persons: parachutist, parachutist in command and passenger in tandem parachute operations, drop zone or owner or operator, jump master, certificated parachute rigger, or pilot.

This links the rigger after he or she has packed the rig as they would not be jumping an un packed parachute!

A lot will come out at the PIA as they are targeting a solution by that time frame.

NOTE: Moderators, could someone cut and paste the posts from here regarding the pack cycle issues, over to the 180 day thread?


Thanks,
MEL

By your interpretation of the law, the FAA should have gone after the rigger when the woman with the wet reserve died at the swoop meet a few years ago.

To the best of my knowledge, they did not.

Why not?

It is because, once the airworthy rig is given to a jumper, continued airworthiness becomes the responsibility of the jumper. That doesn't mean the jumper can do the work required to make a rig airworthy. It means that they are responsible to ensure that when the rig becomes un-airworthy, that it does not get jumped. This continuing responsibility lies with the jumper and the pilot, not the rigger.

Do you run around making sure that every rig you inspected continues to be airworthy? No, you do not. No rigger does. If the jumper ignores the un-airworthy condition of the rig and dies, does the FAA come after you? No, they do not.

My best information is that the new AC 105.2D will contain information much the same as the PIA document I cited on this thread a while ago. http://www.pia.com/piapubs/PIA-180FAQ.pdf is still available on the PIA website.

I know, you didn't like that document either.

[mark 107]

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My best information is that the new AC 105.2D will contain information much the same as the PIA document I cited on this thread a while ago: http://www.pia.com/piapubs/PIA-180FAQ.pdf is still available on the PIA website.

We don't know that, since there is no official PIA input to the rewrite process yet. In any case, changing an FAR requires publishing a Notice of Proposed Rule Making (NPRM) followed by a public comment period, followed by a final rule. Updating an Advisory Circular is not a short-cut.

The FAA will be particularly careful about revisions given their embarrassment over their withdrawal of TSO-C23e just a few days after publication of the "final" rule.

Mark

[masterrigger1 2]

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By your interpretation of the law, the FAA should have gone after the rigger when the woman with the wet reserve died at the swoop meet a few years ago.

To the best of my knowledge, they did not.

Why not?

Because there is not a FAR that states jumping a wet reserve is illegal for one.

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It is because, once the airworthy rig is given to a jumper, continued airworthiness becomes the responsibility of the jumper. That doesn't mean the jumper can do the work required to make a rig airworthy. It means that they are responsible to ensure that when the rig becomes un-airworthy, that it does not get jumped. This continuing responsibility lies with the jumper and the pilot, not the rigger.

One more time....show us in black and white in either the FAR's or an AC that states your theory.

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My best information is that the new AC 105.2D will contain information much the same as the PIA document I cited on this thread a while ago. http://www.pia.com/piapubs/PIA-180FAQ.pdf is still available on the PIA website.

I know, you didn't like that document either.

The part that I did not like is the fact that:
1.It is not an offical Document from the FAA

2. The last two questions were answered by the PIA, not the FAA. At least it was not answered by the legal counsel assigned to the new rule.

Ed Averman, is that person. He is listed as the legal contact for the new rule on the Federal Register.

I spoke directly with him a few days ago.

In that conversation, he explained that the only thing that he was asked to look at was pack dates.

The question of opening and re-closing of containers was never mentioned to him, nor was the legallity of appliances (AADs)and their service dates.


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

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By your interpretation of the law, the FAA should have gone after the rigger when the woman with the wet reserve died at the swoop meet a few years ago.

To the best of my knowledge, they did not.

Why not?

Because there is not a FAR that states jumping a wet reserve is illegal for one.

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It is because, once the airworthy rig is given to a jumper, continued airworthiness becomes the responsibility of the jumper. That doesn't mean the jumper can do the work required to make a rig airworthy. It means that they are responsible to ensure that when the rig becomes un-airworthy, that it does not get jumped. This continuing responsibility lies with the jumper and the pilot, not the rigger.

One more time....show us in black and white in either the FAR's or an AC that states your theory.

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My best information is that the new AC 105.2D will contain information much the same as the PIA document I cited on this thread a while ago. http://www.pia.com/piapubs/PIA-180FAQ.pdf is still available on the PIA website.

I know, you didn't like that document either.

The part that I did not like is the fact that:
1.It is not an offical Document from the FAA

2. The last two questions were answered by the PIA, not the FAA. At least it was not answered by the legal counsel assigned to the new rule.

Ed Averman, is that person. He is listed as the legal contact for the new rule on the Federal Register.

I spoke directly with him a few days ago.

In that conversation, he explained that the only thing that he was asked to look at was pack dates.

The question of opening and re-closing of containers was never mentioned to him, nor was the legallity of appliances (AADs)and their service dates.


Cheers,
MEL

And you have not produced a law that says closing a rig with a battery that has 5.5 months of life left is illegal.

65 says I cannot pack a rig that is not airworthy.

105 says that we must all follow the manufacturer's instructions for AAD maintenance and service. Other than in 105, there is no mention of AADs in the FARs. I have never seen anything from AIRTEC that says I must replace the battery before the stated life limits of 2 years and 500 jumps. Closing the rig with a battery that has 5.5 months of life is not prohibited by the AIRTEC, the manufacturer.

105 states that the rig must be in compliance with inspection and service requirements AT THE TIME OF USE. It doesn't say you cannot own a rig that is not in compliance. It says that the rig must be in compliance at the time of use.

There is no law that says the rig must be in compliance when it is not being used.

In US law, that which is not prohibited is allowed. FARs say I must follow the manufacturer's instructions. The manufacturer does not say to replace a battery that has less life than the inspection interval. Therefore I am allowed to repack a rig as long as the battery has some life left according to the manufacturer's specification of battery life.

Of course, I know full well that you won't agree.

So, let me ask you another question regarding finer parts of the law.

What do you do when you put a mark in the last box on a PD reserve?

Do you hand the rig back to the jumper, or do you send the reserve back to PD?

PD says that the reserve must go back to PD after 40 repacks, and you just did the 40th repack. Is that when you have to send the canopy back?

I suspect you would hand the rig to the jumper, and you would send the canopy back to PD the next time the rig comes back to you for another repack.

If that is what you would do, please explain why the AAD battery should be treated differently from the canopy.

[riggerpaul 1]

Final question. This is theoretical, but please tell us how you think things should work.

Argus has a 1 year battery life per manufacturer instructions.

We go to a 18 month repack interval.

Argus is now illegal to use at any time?

[masterrigger1 2]

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And you have not produced a law that says closing a rig with a battery that has 5.5 months of life left is illegal.

65 says I cannot pack a rig that is not airworthy.

Sure, I did! It is the same one that you posted above.

65 says I cannot pack a rig that is not airworthy

Again, 65 was written when all that you had to pack was a container, a canopy, and sometimes a pilot chute. They were no batteries and AAD's to contend with.
The pack cycle was ony a few days instead of several months.

So I believe (and this is what is being looked at this very moment) that the intent when the rule was written, was to be airworthy for the entire pack cycle.

So that will be determined by the FAA sooner or later.

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105 says that we must all follow the manufacturer's instructions for AAD maintenance and service. Other than in 105, there is no mention of AADs in the FARs. I have never seen anything from AIRTEC that says I must replace the battery before the stated life limits of 2 years and 500 jumps. Closing the rig with a battery that has 5.5 months of life is not prohibited by the AIRTEC, the manufacturer.

Airtec cannot dictate changes to FAR's period. End of story.
You must follow their instructions for maintenance though.
But, if there is a conflict with the manufacturer instructions and the FARs, the FAR's are to be followed not the manufacturer's instructions.

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So, let me ask you another question regarding finer parts of the law.

What do you do when you put a mark in the last box on a PD reserve?

Do you hand the rig back to the jumper, or do you send the reserve back to PD?

PD says that the reserve must go back to PD after 40 repacks, and you just did the 40th repack. Is that when you have to send the canopy back?

I suspect you would hand the rig to the jumper, and you would send the canopy back to PD the next time the rig comes back to you for another repack.

That would be correct.

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If that is what you would do, please explain why the AAD battery should be treated differently from the canopy.

1. The canopy would be good for the entire 180 days of the repack cycle.

2.The batteries would not be.

3. If you had a reserve ride the day after packing the PD canopy it also would not be airworthy.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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Final question. This is theoretical, but please tell us how you think things should work.

Argus has a 1 year battery life per manufacturer instructions.

We go to a 18 month repack interval.

Argus is now illegal to use at any time?

By then there will be a six year battery available....

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

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And you have not produced a law that says closing a rig with a battery that has 5.5 months of life left is illegal.

65 says I cannot pack a rig that is not airworthy.

Sure, I did! It is the same one that you posted above.

65 says I cannot pack a rig that is not airworthy

Again, 65 was written when all that you had to pack was a container, a canopy, and sometimes a pilot chute. They were no batteries and AAD's to contend with.
The pack cycle was ony a few days instead of several months.

So I believe (and this is what is being looked at this very moment) that the intent when the rule was written, was to be airworthy for the entire pack cycle.

So that will be determined by the FAA sooner or later.

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105 says that we must all follow the manufacturer's instructions for AAD maintenance and service. Other than in 105, there is no mention of AADs in the FARs. I have never seen anything from AIRTEC that says I must replace the battery before the stated life limits of 2 years and 500 jumps. Closing the rig with a battery that has 5.5 months of life is not prohibited by the AIRTEC, the manufacturer.

Airtec cannot dictate changes to FAR's period. End of story.
You must follow their instructions for maintenance though.
But, if there is a conflict with the manufacturer instructions and the FARs, the FAR's are to be followed not the manufacturer's instructions.

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So, let me ask you another question regarding finer parts of the law.

What do you do when you put a mark in the last box on a PD reserve?

Do you hand the rig back to the jumper, or do you send the reserve back to PD?

PD says that the reserve must go back to PD after 40 repacks, and you just did the 40th repack. Is that when you have to send the canopy back?

I suspect you would hand the rig to the jumper, and you would send the canopy back to PD the next time the rig comes back to you for another repack.

That would be correct.

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If that is what you would do, please explain why the AAD battery should be treated differently from the canopy.

1. The canopy would be good for the entire 180 days of the repack cycle.

2.The batteries would not be.

3. If you had a reserve ride the day after packing the PD canopy it also would not be airworthy.

Cheers,
MEL

What you are saying, then, is that the airworthyness of the AAD depends on the rig it is in.

That's silly.

A CYPRES(1) (with appropriate maintenance met, of course) with an 18 month old battery in it is airworthy. Plain and simple.

Which rig you put it in doesn't change the airworthiness of that AAD.

But, you say that the airworthiness of the AAD depends on which rig you put it in.

If I put it in a rig that has a natural fiber canopy (still a 60 day repack), the AAD is airworthy.
If I put it in a rig that is all man-made material (180 day repack), the AAD is not airworthy.

By the way, prior to what, 2000 (2001?), there was no mention of an AAD in the FARs at all.

There always was a rule that said I had to wear an approved single-harness, dual-parachute rig with an approved canopy.

By your reasoning - that I must produce a rule that allows things - we were never allowed to use an AAD before the newer rules in 2000(2001?). After all, there was never a rule that allowed them. The rule didn't say "an approved rig with something else that we don't talk about in it." Did it? So, according to your logic, how was it legal to use an AAD before the rule specifically allowed it?

Regarding the PD canopy, the manufacturer says "after the 40th repack". Well, you did the 40th repack. That would qualify for "after". But you say the canopy is still legal, even though that's not what the manufacturer told you. You apply your own rules rather inconsistently.

[chutingstar 1]

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What do you do when you put a mark in the last box on a PD reserve?

Do you hand the rig back to the jumper, or do you send the reserve back to PD?

PD says that the reserve must go back to PD after 40 repacks, and you just did the 40th repack. Is that when you have to send the canopy back?

Not really pertaining to this overall argument so much...but...

There are only 39 boxes on a PD reserve, so when the last box is marked, you haven't hit 40 yet.

Last month I sent a PR-143 back to PD that had 39 repacks (full label). PD completed a porosity test, 30-pound fabric clamp test, visual inspection and line trim check. They also replaced the steering lines. A new label was sewn to the side of the old label that extended the life for another 30 repacks or 18 jumps. Total cost: $32.

Mike

ChutingStar.com

[tdog 0]

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Again, 65 was written when all that you had to pack was a container, a canopy, and sometimes a pilot chute. They were no batteries and AAD's to contend with.
The pack cycle was ony a few days instead of several months.

So I believe (and this is what is being looked at this very moment) that the intent when the rule was written, was to be airworthy for the entire pack cycle.

So that will be determined by the FAA sooner or later.

We all know how you interpret the rules. That argument is now a dead horse... You won't change our minds now sooner than we will change yours - although it inspired me to talk to many people (including the manufacture and service center of the most popular AAD)... I learned a lot - so thank you for your debate.

Here is the next question.

I talked to a few aircraft owners and mechanics about inspections and components that will time out between inspections. It is clear that many components time out between inspections and the sole responsibility to track these engine times, landing count, and dates since last maintenance is the responsibility of the owner/operator of the aircraft...

If an FAA official came to you, (anyone on dropzone.com, not just MEL) and said, "We are thinking of publishing an interpretation that states the AAD need not be airworthy for the entire packjob window, and the owner will be responsible for taking the rig out of service when the component times out... What do you think, from a safety and operation standpoint?"

What would your answer to them be? What incidents and/or accidents would you cite to justify your argument?

If you argue something like, "skydivers are not trained enough on their gear or are likely to bend the rules intentionally" - you must show stats to prove skydivers are different than general aviation aircraft owners, that riggers cannot train their customers better AND that stricter rules will cause skydivers to behave differently...

P.S. I know a DZ that is tracking reserve dates in their waiver/manifest database based upon the soonest component to time out - battery or packjob, thus protecting themselves and keeping their customer's honest in the same way they won't let an 181 day rig be jumped.... So there are solutions to this at the DZ level too.

[riggerpaul 1]

Oops. I should have looked at the canopy before I posted.

Now, for some confusion... the writing below the boxes says the canopy must receive a permeability test within the last 25 jumps or 40 repacks. How do we know about that 40th repack if there are only 39 boxes? (I didn't really ask that question. I don't want to open yet another can of beans.)

Nice to hear that one came back. I've never heard anyone say that before.

[masterrigger1 2]

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What you are saying, then, is that the airworthyness of the AAD depends on the rig it is in.

That's silly.

That is not what I said..you need to re-read the post!

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By the way, prior to what, 2000 (2001?), there was no mention of an AAD in the FARs at all.


.....

By your reasoning - that I must produce a rule that allows things - we were never allowed to use an AAD before the newer rules in 2000(2001?). After all, there was never a rule that allowed them. The rule didn't say "an approved rig with something else that we don't talk about in it." Did it? So, according to your logic, how was it legal to use an AAD before the rule specifically allowed it?

It was before that as the Sentinals and FXCs were being installed in the Early 70's. At least the Sentinal Pin Pullers were being installed then.


MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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We all know how you interpret the rules. That argument is now a dead horse...

So Travis, How do I interpret the rules?

I personally think with the 30 plus years of working with Federal regulations (NRC and CFR's) and almost 20 years of FAA regs puts me in a pretty good light of understanding them.

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I talked to a few aircraft owners and mechanics about inspections and components that will time out between inspections. It is clear that many components time out between inspections and the sole responsibility to track these engine times, landing count, and dates since last maintenance is the responsibility of the owner/operator of the aircraft...

Travis,
The difference in regards to aircraft is that there are rules within Part 91 that states the operator of that aircraft shall comply with airwothiness directives.

There are no such rules within 65,105, or AC-105-2C for the jumper to maintain airworthiness directives.

If you care to read the FAR's again knowing this, I believe you may have another opinion.


BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[tdog 0]

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So Travis, How do I interpret the rules?

I personally think with the 30 plus years of working with Federal regulations (NRC and CFR's) and almost 20 years of FAA regs puts me in a pretty good light of understanding them.

You have pretty much told us exactly how you interpret them, "personally"... I am not going to restate your opinion....

You might have 30 years of experience... I, on the other hand, talked with over 10 qualified people on this issue including people with rather impressive credentials (lawyers specializing in FAA parachuting regulations, manufactures (more than one), pilots, mechanics, DZOs, the USPA, etc). I am not posting their names or job titles because our conversations were not for public consumption, but there are plenty out there who others can contact for their own research.

My actions and how I handle the AAD unit life situation, which I am not going to post publicly my exact procedures and policies, are based upon the combined professional recommendations of these professionals because I am not egotistical enough to believe I know everything (despite my persona on dropzone.com)

My online "debate" with you is because there seems to be a consensus by almost everyone - other than you - that a rigger CAN seal a rig with an AAD that will "expire" in the next 180 days... That's not to say all the experts recommend it, nor are doing it.

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Travis,
The difference in regards to aircraft is that there are rules within Part 91 that states the operator of that aircraft shall comply with airworthiness directives.

There are no such rules within 65,105, or AC-105-2C for the jumper to maintain airworthiness directives.

If you care to read the FAR's again knowing this, I believe you may have another opinion.

You have interesting logic... You look for what is omitted from the rules instead of what is in the rules. As someone else said, the laws in the USA are written with the understanding that unless it is specifically prohibited or regulated, by default it is allowed.

But, for the sake of learning - which specific airworthiness directive relating to AADs do you think applies to the issue of time limited components in AADs?


P.S. You did not answer my question in the last post... I suggested that this debate between you and I was a dead horse, and I asked everyone, including you, to think about what the rules SHOULD be - if we had an opportunity to inspire the FAA to clarify. Do you have an answer to that?

[riggerpaul 1]

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What you are saying, then, is that the airworthyness of the AAD depends on the rig it is in.

That's silly.

That is not what I said..you need to re-read the post!

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By the way, prior to what, 2000 (2001?), there was no mention of an AAD in the FARs at all.


.....

By your reasoning - that I must produce a rule that allows things - we were never allowed to use an AAD before the newer rules in 2000(2001?). After all, there was never a rule that allowed them. The rule didn't say "an approved rig with something else that we don't talk about in it." Did it? So, according to your logic, how was it legal to use an AAD before the rule specifically allowed it?

It was before that as the Sentinals and FXCs were being installed in the Early 70's. At least the Sentinal Pin Pullers were being installed then.


MEL

You didn't answer my question.

So, I'll ask again.

Prior to 2001 there was no mention of an AAD in the FARs.

Was it legal to use an AAD on a reserve before there was a regulation that allowed it?

Why?

[masterrigger1 2]

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You might have 30 years of experience... I, on the other hand, talked with over 10 qualified people on this issue including people with rather impressive credentials (lawyers specializing in FAA parachuting regulations, manufactures (more than one), pilots, mechanics, DZOs, the USPA, etc). I am not posting their names or job titles because our conversations were not for public consumption, but there are plenty out there who others can contact for their own research

Do you not think I discussed the matter with people of the same or higher creditials?

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You have interesting logic... You look for what is omitted from the rules instead of what is in the rules. As someone else said, the laws in the USA are written with the understanding that unless it is specifically prohibited or regulated, by default it is allowed.

Laws and regulations differ for the most part.
Laws state what you cannot do.

Regulations mostly state what is allowed.

Regulations are governed by laws.

I.e. ..you violate a regulation, you break a law that states you have to follow FAR regulation.

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P.S. You did not answer my question in the last post... I suggested that this debate between you and I was a dead horse, and I asked everyone, including you, to think about what the rules SHOULD be - if we had an opportunity to inspire the FAA to clarify. Do you have an answer to that?

Yes I do. There will be a meeting just before the offical start of the PIA. Several people including myself will be there to try and define what should be done.Several items are on the agenda as I hear.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[masterrigger1 2]

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You didn't answer my question.

So, I'll ask again.

Prior to 2001 there was no mention of an AAD in the FARs.

Was it legal to use an AAD on a reserve before there was a regulation that allowed it?

Why?

Paul,
Back in the day, most riggers pretty much did what they wanted. They even built non-TSO'd rigs for jumping. It seemed no one really cared at that time.

Also,the AAD's first were installed on the outside and the FAA did not really care since there were not inside the container.

Then field approvals came along.


... And now, we are here debating what needs to be done with them.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[riggerpaul 1]

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... And now, we are here debating what needs to be done with them.

Cheers,
MEL

No, actually, that's not at all what we are doing.

What we are doing is debating whether existing law says the things you say it does.

You have claimed that there is existing law that says I shall not close a rig if the AAD battery will expire before the next repack.

You have claimed that I am breaking the law right now if I do that.

You have claimed that the existing law does not make the pilot and jumper responsible for ensuring that required maintenance is performed to the manufacturer's specification.

You have claimed that existing law burdens me with a forward looking responsibility for the airworthiness of a rig.

We are not debating "what needs to be done".

We are debating your claims that laws exist right now that say the things you say.

[masterrigger1 2]

Paul,
I have pointed out the FAR's from where I get my theories.
Just go back and read them.They are in black and white..

There are enough people in agreement within the FAA that they are "issues".

You and a handful of other just do not agree. It is that simple.

End of Story!

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[tdog 0]

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You and a handful of other just do not agree. It is that simple.

End of Story!

MEL

Handful????

To all readers:

This 100 post long debate started on December 7th when I posted a link to SSK's post (the sole US service center for Airtec products).

http://www.dropzone.com/cgi-bin/forum/gforum.cgi?post=2385171;#2385171

MEL, who likes to debate with me, and I admit I like to debate back - has debated every point from the fact SSK is not "the manufacture", so following their instructions is not allowed, to details in the FARs.

I have contacted many people, including the author of the post above that started this thread. I have tried to learn a lot.

I am questioning if I am wrong - as I am not trying to bend the rules.

So this is an open invite. If you are a rigger in the USA - or have some legal expertise in the FARs - this is an open invite to PM me or post in this thread. For every PM I get, I will post online a "pack" or "no pack" vote, but protect your identity.

I promise to listen and not waste your time with debate... I just want to hear from others...

MEL, if you want, I can send you my cell phone so you can have your experts call me to educate me.

With data, I will admit I am wrong and say MEL is right.

[chutingstar 1]

Yes, I will pack a rig with an AAD that will or may need service or new batts before the due repack date for a variety of reasons, but always with a note on the packing data card of the applicable due date.

Yes, I will open/reclose a reserve/container to replace a battery, service an AAD, install/remove an AAD or replace/shorten a closing loop. The actual work will be noted on the packing data card for what was specifically completed.

No, I'm not 100% convinced I'm right in how I handle this, but I am certain enough to do it at this time. Mel does make an interesting point and I'm continuing to read on how this plays out. But I'm not changing my interpretation as of yet.

Mike

ChutingStar.com

[masterrigger1 2]

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Yes, I will open/reclose a reserve/container to replace a battery, service an AAD, install/remove an AAD or replace/shorten a closing loop. The actual work will be noted on the packing data card for what was specifically completed.

Mike,
Do you repack the parachute if you service the AAD? The below regulation states that a seal is to be placed on the parachute only after packing it .

This is Reg is cut and dry/black and white. It also is one of the main reasons the FAA is srambling to fix it., if it needs fixed.

§ 65.133 Seal.
top
Each certificated parachute rigger must have a seal with an identifying mark prescribed by the Administrator, and a seal press. After packing a parachute he shall seal the pack with his seal in accordance with the manufacturer's recommendation for that type of parachute.

This reg is cut and dry/black and white and leaves no doubt that you must pack a parachute to seal it.

This is also the reason that the FAA is scrambling around.


Here's the reason, 65.111 states that you cannot pack an unairworthy parachute.
The intent used to be for the entire pack cycle or that's what most of us think.

I have asked for a ruling on this to come out in AC-105.
They could define it either way.

1.If it is for the entire pack cycle, they have to do nothing to the rest of Part 65.

2.If the intent is for the day that the rigger packs it only, then several parts of 65 has to be changed.

The above rule is one of them. It will have to be changed;
1. To allow a seal to be placed after maintenance and packing.
2. 65.131 (records) will have to be changed to include a place or paragraph for the AAD maintenance issues.
3. Several changes to rigger privileges throughout 65 would also have to be made.

So, for right now, what is known by Legal is that if you open the parachute, it has to be repacked to seal it!


Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[chutingstar 1]

Quote

§ 65.133 Seal.
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Each certificated parachute rigger must have a seal with an identifying mark prescribed by the Administrator, and a seal press. After packing a parachute he shall seal the pack with his seal in accordance with the manufacturer's recommendation for that type of parachute.

This reg is cut and dry/black and white and leaves no doubt that you must pack a parachute to seal it.

But if you read it that literally, then you can't even reseal the rig if the seal gets broken.

Do you inspect/pack the reserve if a rig you just packed last week comes back to you with a broken seal since it must be sealed only after packing it?

Anyway, yes, I do seal the rig after packing it. I also seal the rig if the seal gets broken. And the seal can get broken just from normal use or from myself when having to put a new ripcord in, or service an AAD, or the like, within the same repack cycle.

I understand how you are interpreting the reg...just not convinced we have to take it that literally. But, you could be right...we'll see...

Mike

ChutingStar.com

[peregrinerose 0]

Quote

§ 65.133 Seal.
top
Each certificated parachute rigger must have a seal with an identifying mark prescribed by the Administrator, and a seal press. After packing a parachute he shall seal the pack with his seal in accordance with the manufacturer's recommendation for that type of parachute.

I'm not sure I'm reading that the same way you are. It says after packing, you must seal the pack. It does NOT say that the ONLY time you may seal a pack is after packing it.

With your interpretation, a broken seal could not be re-sealed without packing under any circumstances. Even if the seal is broken right in front of the rigger that packed it by a clumsy student learning rig parts, it would require a full repack.

I could be wrong, and I agree with almost everything you've written in this thread so far, but not your interpretation of this particular line.

Do or do not, there is no try -Yoda