Rigger and Jumper Responsibilities

[Gary73 10]

The extension of the repack cycle to 180 days has re-opened an old debate regarding whether an AAD has to be "good" for the entire repack cycle. Some very experienced jumpers/riggers believe that it does, but the FAA and PIA have reiterated the division of responsibility:

FAA (in response to a question I submitted on their website):
The rigger is responsible for the condition of the reserve parachute at the time he/she repacks the reserve parachute. The Automatic Activation Device battery does not have to be good for the entire 180 days. It is the parachute owner who is responsible for maintaining the parachute in airworthy condition. The decision to complete a repack knowing that the Automatic Activation Device battery will not reach the entire 180 days needs to include the owner of the parachute so he/she knows his/her options and when the next scheduled maintenance is due on his/her parachute.

PIA:
http://www.pia.com/piapubs/tb/TB-252.pdf

I hope this resolves any doubts that people may have.

"Extraordinary claims require extraordinary evidence." - Carl Sagan

[councilman24 37]

Quote

The decision to complete a repack knowing that the Automatic Activation Device battery will not reach the entire 180 days needs to include the owner of the parachute so he/she knows his/her options and when the next scheduled maintenance is due on his/her parachute.

"The decision...." It is a decision. Some riggers believed it was illegal. Some riggers were and are willing to leave it to the owner. Some riggers weren't whether legal or not, knowing that most owners wouldn't comply and the unairworthy and illegal to use rig would be in the air with their seal on it. Some of those riggers may now, with the longer time between service and the "extra" time early AAD service might cost the owner, change their decision and allow something that becomes unairworthy before the next inspection is due out the door. Some may not change their decision.

But it IS the decision of the rigger. Nothing MANDADATES that any rigger pack a rig that will become unairworthy before the next inspection is due, or any rig for that matter.

Yes, in theory there is no liability. But the jury in the civil lawsuit isn't made up of FAA officials.

NOTHING has changed, either with the change in inspection cycle length or the clarifying documents issued. The only thing that has been made clearer by some FAA officials is that opening a rig, doing none inspection and repack maintenance and resealing the rig is legal. And even that is still up for debate.

No doubts, the rigger still gets to decide what he/she is willing to do. And the customer get to decide who they are going to take their business to.

And DZO's and pilots have to know not only when the next inspection is due but when any particular components airworthyness may change.

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

[BKR 0]

It is seems to me one point has been forgotten, the AAD is not concerned by any certification. This means a Rigger is packing a certified parachute in which a non certified unit is set.... It is just under the responsability of the manufacturer to be sure there will be no interferences between the AAD and a normal manual use of the reserve parachute. Because of this point, what would be the responsability????

Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468

[councilman24 37]

In the U.S. AAD's ARE regulated in that under the FAR's even if not certified. They must be maintained according to the manufacturer's instructions. That maintainence doesn't require the services of a rigger except for installation of the pockets and installation of the unit into the pocket (the last one was debatable but the FAA at one time held that it took a Master Rigger to put a unit in a pocket. The did back off of that position to a Senior rigger.

And U.S. juries don't care. Saying that I recognize that I still haven't heard of a case where the RIGGER has been sued. Everybody else BUT the rigger. Anybody have any cases?

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

[BKR 0]

Terry,

Do you have any official paperworks about this, I am interested..?
Thanks

Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468

[Gary73 10]

You are correct that the rules have not changed, but some jumpers and riggers have had an incorrect understanding of the rules, so I hope to correct that.

Certainly a rigger has the right to either insist on doing AAD maintenance (including battery change) or decline to pack a rig, but both the rigger and the owner should be clear on the reason. Namely, the rigger shouldn't tell the owner that the FARs require him to replace a battery when it's really just the rigger's preference.

None of this changes the fact that it really is a good idea to go ahead and do any AAD maintenance that will be due during the upcoming pack cycle. But there may be circumstances under which the owner may not have the time to wait three weeks for CYPRES maintenance (e.g., reserve ride right before a trip) or may not plan to use the rig for the full 180 days (e.g., shipping out next month for a year in the desert).

"Extraordinary claims require extraordinary evidence." - Carl Sagan

[Gary73 10]

Quote

Terry,

Do you have any official paperworks about this, I am interested..?
Thanks

FAR 105.43 (c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.

"Extraordinary claims require extraordinary evidence." - Carl Sagan

[BKR 0]

A rigger is responsible of what is certified, I do not understand how can he be responsible of an item which is not certified?? You can put a puppet into the reserve container till it doesn't interfered with its normal use....

Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468

[billvon 3,108]

>A rigger is responsible of what is certified, I do not understand how can he
>be responsible of an item which is not certified?

?? Cypres closing loop material is not "certified." Yet many riggers regularly construct new closing loops and use them in a critical location in the rig. And yes, they're responsible for that.

[GLIDEANGLE 1]

So... how does this affect DZOs and pilots?

As I understand FAR 105.43 (c), both the user and the pilot are accountable for the AAD (if present) being properly maintained.

When jumping at a new DZ I have only been asked for my reserve packing date... never any info about my AAD. I presume that DZOs believed that if the reserve was good, so was the AAD.

If riggers choose to follow the more liberal guidelnes you cite... DZOs will need to begin to ask about BOTH the reserve canopy and the AAD (if present). If they don't do this, and an incident occurs with an out of date AAD in a current reserve, the pilot could be in a heap of trouble.

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

[BKR 0]

Quote

>A rigger is responsible of what is certified, I do not understand how can he
>be responsible of an item which is not certified?

?? Cypres closing loop material is not "certified." Yet many riggers regularly construct new closing loops and use them in a critical location in the rig. And yes, they're responsible for that.

Closing loop??? The AAD is not,certified at all, the kind of closing loop which must used must be defined by the H/C manufacturer in its definition file when submited to the FAA ..

Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468

[councilman24 37]

As well as the DZO.

105.3 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.


105.43 No person may conduct a parachute operation using a single-harness, dual-parachute system, and no pilot in command of an aircraft may allow any person to conduct a parachute operation from that aircraft using a single-harness, dual-parachute system, unless that system has at least one main parachute, one approved reserve parachute, and one approved single person harness and container that are packed as follows:

(a) The main parachute must have been packed within 180 days before the date of its use by a certificated parachute rigger, the person making the next jump with that parachute, or a non-certificated person under the direct supervision of a certificated parachute rigger.

(b) The reserve parachute must have been packed by a certificated parachute rigger-

(1) Within 180 days before the date of its use, if its canopy, shroud, and harness are composed exclusively of nylon, rayon, or similar synthetic fiber or material that is substantially resistant to damage from mold, mildew, and other fungi, and other rotting agents propagated in a moist environment; or

(2) Within 60 days before the date of its use, if it is composed of any amount of silk, pongee, or other natural fiber, or material not specified in paragraph (b)(1) of this section.

(c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.



With the latest change in 105 they included everybody, including the TANDEM PASSENGER. All are responsible for conducting a 'parachute operation' according to 105.43. And yes, if riggers start using the more liberal choice of letting the AAD expire during an inspection cycle DZO's need to have a separate field for AAD.

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

[BKR 0]

Terry,
Give me an answer to this..
(c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.

How can a NON CERTIFIED DEVICE can be included into a certified H/C when the TSO say "it is under the responsability of the manufacturer of an approved H/C to include any accessories which can affect the normal use of the reserve opening... Can you give me an official answer to this??
It's late, I will read this in 8 hours from now..
Cheers

Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468

[councilman24 37]

I'm not the FAA. I can't give you offical anything.

Tell me which of the 3 active TSO's your quoting. But, the H/C don't include links and some don't include bridle or pilot chuste. I don't think there is any conflict there. AAD manufacturer's say 'Hey, I want people to put this on your reserve.' H/C manufacturers, in the case of Airtec, delayed because Vigil never asked, say,"Okay, lets test it and here is the best way. Please tell people to do it this way.' AAD man. says okay. Then, many years later FAA says 'Oh, if you have an AAD (even through we don't approve or regulate them) you have to maintain it according to the manufacturer.' Depended on who had the right lobbiest in Washington. I've been told it is the only non certified accessory or component that the feds regulate.

The point of the manufacturer's approval to the AAD company is that it DOESN't effect the NORMAL USE. i.e. pulling the ripcord.

Don't try to understand the FAR's, just accept the 80 different interpretations there are.

BTW puppets aren't specifically discussed in the FAR's. AAD's are.

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

[riggerpaul 1]

Terry responded with most of what I am interested in hearing about this question.

But I want to add a little something for your consideration.

You say you are worried about your pilot being at risk. You say "If riggers choose to follow the more liberal guidelnes you cite... DZOs will need to..."

The best thing you can do to protect your pilot is to know the regulations and to be certain that you are in compliance with them. Take the responsibility on yourself. Don't put the burden on somebody else.

Be sure that you don't try to use that rig when the repack is no longer sufficiently recent. Make sure that your friends don't pencil pack. Don't go to the boogie and then find our that you don't have a current rig.

If you are not willing to handle the responsibility, you are free to tell your rigger to be ultra-conservative with you. Tell him to replace the battery that won't be legal all the way until the next repack. Tell him never to open the rig without doing a full I&R. If you want to spend your money to be sure that you don't have to be responsible for these things, you are free to make that choice.

But if a person is aware of the requirements and handles them, why should we tell him that he must replace a battery that has nearly 25% of its life left? Maybe he's going to put the rig away for the season before that battery expires. Maybe he's going to be away from jumping and doesn't want to replace the battery now.

The method you seem to support says he should not be allowed to use his rig even though he has a battery that still absolutely usable. And you seem to think this is right because there is a chance that he might use it after the battery has expired.

You are free to substitute your money for your responsibility if you like.

Does that mean that everyone else must do the same?

[GLIDEANGLE 1]

Rigger Paul:

I am not sure how my posting implied that I am a slacker who is looking for other folks to mind my busines, or that I support anything other than the DZOs tracking BOTH the reserve repack date and AAD maintenace due date to protect themselves and thier crew.

I never proposed that any jumpers or riggers change the decisions that they make about timing of repacks and timing of AAD service.

All I suggest is that in order to protect themseleves and their crew it may now be prudent for DZOs to verify that both the reserve repack date and the AAD service date are current before letting a jumper on the plane.

Without a doubt jumpers and riggers need to act responsibly, but that was not my point.

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

[tombuch 0]

Quote

You say you are worried about your pilot being at risk. You say "If riggers choose to follow the more liberal guidelnes you cite... DZOs will need to..."

A good rigger can address this issue as well. The reserve data card can include a note listing the battery and maintenance due dates for the AAD. That way anybody inspecting the data card can easily determine if the AAD is within service parameters. That's an especially nice thing to do for customers so they always know when they will be facing an expense item. The rigger is not required to list this information in a specific easy to find location, but it would sure make life nicer for DZO's, jumpers, and pilots.

As an aside, it is my understanding that when a rigger does any work that would affect airworthiness, including the removal or installation of an AAD or AAD battery, that work should be noted on the data card. So, a DZO or customer could read the service history of the rig and determine when time critical work was done, and then compute when the next due date is. That assumes the rig has a data card with full maintenance history, but when a data card is completely replaced that history is lost.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

[lilchief 1]

...buy a cypres 2 and avoid trouble?

"Once you have tasted flight, you will forever walk the earth with your eyes turned skyward, for there you have been and there you long to return." - Da Vinci
www.lilchief.no

[billvon 3,108]

> The AAD is not,certified at all,

Right. But compatible AAD's are specified by the H/C manufacturer.

>the kind of closing loop which must used must be defined by the H/C
>manufacturer in its definition file when submited to the FAA ..

Well, no. The closing loop material just has to be one of the types OKed by the manufacturer; it doesn't have to be the exact same material. It just has to be approved by the manufactuer - like an AAD.

[riggerpaul 1]

It has always been prudent for everybody involved to be as informed as possible.

I apologize that I implied you were a slacker.

Please take my comments then as general comments to the world, not specific comments to you.

There was that whole long thread a short while back where people were saying it has never been legal to close a rig with a battery that would not make it to the next repack. There were a number of influential personalities that said or strongly implied that jumpers could not be trusted to be sure that there gear was legal, and that the only way to be sure was to do things like early battery changes.

I have problems with that whole line of thought. Riggers are not the policemen of rigs, they are the mechanics.

Anyway, it sounded to me like you were just realizing that DZOs should be doing this sort of thing. I was wrong. I apologize.

You said "If riggers choose to follow the more liberal guidelnes you cite..." and this made me think that you thought that riggers weren't authorized to do this already. I apparently read too much into it. I was wrong. I apologize.

I know that when I check a rig in at the dz, I check for all these things on the packing data card. The information is there. It sounded to me like the dz didn't even look at your card, and that was amazing to me. Sometimes I cannot find it, and then I refer the matter to higher authorities for them to decide what to do. It is true that the manifest software doesn't track all the information. But I know that the riggers who will be servicing these rigs are conscientious, and don't expect that we have many problems in this area. At least, if they are rigs that become regular rigs at our dz, and that they are using riggers that frequent our dz.

Anyway, I made some assumptions that I should not have about your post. I should not have sounded as though I was singling you out for criticism. Please don't think too horribly about me.

[riggerpaul 1]

Yes, a good rigger can make this easier. Earlier in my rigging career, I was not as careful as I am now about making these things clear. But now I try to make it very clear in the main area when things like battery changes and AAD maintenance has been done.

My post was to a great extent reacting to the notion that the whole issue could be avoided by doing early battery replacements. I had incorrectly presumed that GLIDEANGLE was suggesting this position.

Some have said this is required by the law. But more and more we are hearing that it is not and probably never has been.

Personally, I think we should have at least 2 logs. One for the reserve, and one for the AAD. It is also possible that there should be a third for the container.

This won't help if people lose them, but it would at least make it possible for the log to properly follow the equipment whose history it records.. Having only 1 log is just asking for confusion.

[GLIDEANGLE 1]

Apology accepted.
Wanna beer?

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

[BKR 0]

Quote

> The AAD is not,certified at all,

Right. But compatible AAD's are specified by the H/C manufacturer.

>the kind of closing loop which must used must be defined by the H/C
>manufacturer in its definition file when submited to the FAA ..


Well, no. The closing loop material just has to be one of the types OKed by the manufacturer; it doesn't have to be the exact same material. It just has to be approved by the manufactuer - like an AAD.

This is what I want to say

Jérôme Bunker
Basik Air Concept
www.basik.fr
http://www.facebook.com/pages/Le-Luc-France/BASIK-AIR-CONCEPT/172133350468