Racer counts as chest ? in a rigger exam

[rapaz 0]

Anyone knows why Racer reserve packjobs can be count as chest packjob when you take the rigger test??
Also unaproved TSO rig packjobs counts for the FAA or not??

Nicolino

[GLIDEANGLE 1]

Re NON-TSO gear:

In USA some military gear is legal for civilian use w/o TSO. Packing that would probably be acceptable for the 20 pack job requirement. (or the 100 pack job for master rigger).

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

[captain1976 0]

Absolutely! And you can use it as the seatpack or chest since the SST originally was just a chest mount sewn to a piggyback rig. it’s the same packing procedure.


Not quite sure but I can't remember reading anything in the regs about having to use airworthy or TSO rigf. Many courses including my own used some real junk including condemned canopies. Maybe someone else can answer that.

You live more in the few minutes of skydiving than many people live in their lifetime

[riggerpaul 1]

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Absolutely! And you can use it as the seatpack or chest since the SST originally was just a chest mount sewn to a piggyback rig. it’s the same packing procedure.


Not quite sure but I can't remember reading anything in the regs about having to use airworthy or TSO rigf. Many courses including my own used some real junk including condemned canopies. Maybe someone else can answer that.

My recollection is that there have been changes in the way we can use Racer pack jobs in certification questions.

I've send a PM to John Sherman to see if he has the definitive information.

-paul

[PhreeZone 20]

A more modern interpretation of the regulations is that no one can repack a reserve that is to be jumped unless that person is a rigger, not just under the supervision of one anymore. That means that all of those pack jobs that riggers in training make are not allowed to be on real rigs that will see the air, they are condemned to ground only rigs. With that as the interpretation I don't see how they could not count a condemned canopy pack job as valid as long as all the manufacturers instructions were complied with.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[riggerpaul 1]

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A more modern interpretation of the regulations is that no one can repack a reserve that is to be jumped unless that person is a rigger, not just under the supervision of one anymore. That means that all of those pack jobs that riggers in training make are not allowed to be on real rigs that will see the air, they are condemned to ground only rigs. With that as the interpretation I don't see how they could not count a condemned canopy pack job as valid as long as all the manufacturers instructions were complied with.

First off, there is still some controversy regarding that recent interpretation of the regulations. Funny it should be mentioned now. I just has a few messages with Terry Urban about this very question. The gist seems to be that there is substantial support for the new interpretation being tossed. I guess it doesn't really matter though, if the FAA says that's the was it is, that's the way it is - at least for now.

Anyway, that being said, I don't see where the new interpretation means you can only use condemned gear.

What it says to me is that another rated rigger must repack it after the candidate does. That surely sucks if you are using PD reserves where each repack is counted.

BTW - I got a response from John Sherman about the classification of a Racer reserve. The current position of the FAA, which is also widely contested, is that a Racer has a back type reserve parachute.

-paul

[riggerrob 643]

The primary reason SST (predecessor to Racer) could be listed as back or chest was because the same Pop-Top reserve container could be sewn to an SST harness to become a "back" or could be sewn to a Para-Cushion harness to become a"seat."

The original reason the Vector and Racer manuals said that "..." was because skydivers were in the process of transitioning from chest to piggyback reserves.

With few back-rated riggers, the FAA allowed new sport containers to be packed by chest-rated riggers.

The FAA changed their attitude around the turn of the century (year 2000).
Since Racers had diverged so far from the original Pop-Top, chest-mounted reserve (tapered container, adjustable closing loop, freebag, Cypres, RSL, Speed bag, etc.), the FAA said that Racer or Vector reserve could no longer be recorded as chest or seat, only back.

IOW a military-surplus (chest rated) rigger would not recognize half the parts in a modern Racer reserve container.

[PhreeZone 20]

Correct, the current interpretation means that if a rigger in training wants to repack their rig under supervision they are free to do that, but then they need to get another rated rigger to repack it if they want to jump it. I personally think this sucks and is just putting more wear on components.

Here is one for you to think about, is there anything that would not let you could logging of a main as a packjob towards the 20 supervised? I know the Forest Service (smoke jumpers) and the Military keep full records on the mains and the reserves and rumor was the Forest Service saw them as the same thing for paperwork purposes.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[riggerrob 643]

That would count as "20 supervised main pack jobs" a "nice to know", but not mandatory for earning an FAA rigger rating, because the FAA only counts reserve pack jobs.
Candidates - for FAA Senior Rigger - need to show written proof of having packed 20 RESERVES under the supervision of an FAA rigger.

[mark 107]

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Correct, the current interpretation means that if a rigger in training wants to repack their rig under supervision they are free to do that, but then they need to get another rated rigger to repack it if they want to jump it. I personally think this sucks and is just putting more wear on components.

That is the current interpretation of a very few riggers, including a DPRE or two. It is not the current interpretation of the FAA as a whole, although some FSDOs have been convinced by local riggers to interpret the regulation that way.

That view arises from the truly horrible job the FAA did with the language changes of 2001. The regulation as written (and quite sensibly largely ignored by most FSDOs) limits supervision to main pack jobs, which means we cannot supervise reserve pack jobs under any condition. Under such a reading, any "supervision" done after 2001 doesn't count, and under such a reading, rigger tickets depending on pack jobs after that were issued improperly. Ludicrous, but that is the logical result of the tortured reasoning of those few riggers.

A better perspective is to consider that a rigger may use any tools he needs or wants for any task he is qualified for, including packing. Sometimes I use a very sophisticated tool.

Mark Baur

[riggerpaul 1]

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That would count as "20 supervised main pack jobs" a "nice to know", but not mandatory for earning an FAA rigger rating, because the FAA only counts reserve pack jobs.
Candidates - for FAA Senior Rigger - need to show written proof of having packed 20 RESERVES under the supervision of an FAA rigger.

I wouldn't argue that when you go to the FAA, they will say that they want to see that you packed 20 reserve parachutes.

But, in fact, the regulation does not say "reserve parachutes", it only says "parachutes".

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FAR 65.115.a - (a) Present evidence satisfactory to the Administrator that he has packed at least 20 parachutes of each type for which he seeks a rating, in accordance with the manufacturer's instructions and under the supervision of a certificated parachute rigger holding a rating for that type or a person holding an appropriate military rating;

Now, for all practical purposes, we don't log our main parachute packing. So, it would not commonly be possible to "present evidence" of main pack jobs.

And also for all practical purposes, when you go to a rigging class, you are likely going to pack and log reserve parachute pack jobs, since that's what they are trying to teach you.

But a back pack parachute is a back pack parachute, main or reserve. Just one more bit of silliness in our FARs.

Consider this - if you are a rigger who holds ONLY a chest rating, I do not believe you can legally pack a back pack main parachute for another person, because you do not hold a back rating. And we are only supposed to pack parachute for other people when we have the correct type rating.

Of course, this may be a moot point, because nobody really seems to care much about the legalities of main parachute packing in the first place.

-paul

[riggerrob 643]

I suspect that the original intent of the FAR got mangled beyond recognition by FAA lawyers.

The original intent was that rigger candidates would pack 20 reserves under supervision while training. If they packed more than 30 reserves under supervision then they were slow learners or were abusing the system.

IOW Packing reserves under supervision is only a "temporary" practice, only done during training, and only done before a candidate tests for an rating.
Whether those practice reserves were airworthy ??? who cares ??? candidates were being trained and evaluated on their packing skills.

OTOH Packing main parachutes - under supervision -is a standard practice, required (by FARs) every time a main parachute is packed.

[riggerpaul 1]

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I suspect that the original intent of the FAR got mangled beyond recognition by FAA lawyers.

I am sure that you are right about this.

But that leaves the other part of what I was discussing.

Is it legal for an unsupervised rigger who holds only a chest rating to pack a back pack main for someone else?

[mark 107]

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But, in fact, the regulation does not say "reserve parachutes", it only says "parachutes".

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FAR 65.115.a - (a) Present evidence satisfactory to the Administrator that he has packed at least 20 parachutes of each type for which he seeks a rating, in accordance with the manufacturer's instructions and under the supervision of a certificated parachute rigger holding a rating for that type or a person holding an appropriate military rating;

Now, for all practical purposes, we don't log our main parachute packing. So, it would not commonly be possible to "present evidence" of main pack jobs.

And also for all practical purposes, when you go to a rigging class, you are likely going to pack and log reserve parachute pack jobs, since that's what they are trying to teach you.

But a back pack parachute is a back pack parachute, main or reserve. Just one more bit of silliness in our FARs.

This is a common misinterpretation, arising from casual or imprecise language. In normal conversation, we use "type" to mean "kind" or "sort." In that sense, a skydiving main canopy is usually worn on the back, so it is a kind of back parachute; a base canopy is usually worn on the back, so it is a kind of back parachute; and so on.

However, for the FAA, "type" has a specific meaning. It is short for "approved type," one manufactured under a type certificate, or under a TSO, or a personnel-carrying military parachute . For the FAA, a main parachute is not "typed.". A main parachute is not a back, seat, or chest "type."

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Consider this - if you are a rigger who holds ONLY a chest rating, I do not believe you can legally pack a back pack main parachute for another person, because you do not hold a back rating. And we are only supposed to pack parachute for other people when we have the correct type rating.l

14 CFR 65.125(c) specifically exempts us from having to comply with 65.129(a)(the requirement for a type rating) when we pack, maintain, or alter a main parachute. 65.125(c) allows a certificated rigger, without regard to type rating, to pack a main. A chest-only senior rigger may certainly pack a main canopy for someone else to use.

Mark

[riggerpaul 1]

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But, in fact, the regulation does not say "reserve parachutes", it only says "parachutes".

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FAR 65.115.a - (a) Present evidence satisfactory to the Administrator that he has packed at least 20 parachutes of each type for which he seeks a rating, in accordance with the manufacturer's instructions and under the supervision of a certificated parachute rigger holding a rating for that type or a person holding an appropriate military rating;

Now, for all practical purposes, we don't log our main parachute packing. So, it would not commonly be possible to "present evidence" of main pack jobs.

And also for all practical purposes, when you go to a rigging class, you are likely going to pack and log reserve parachute pack jobs, since that's what they are trying to teach you.

But a back pack parachute is a back pack parachute, main or reserve. Just one more bit of silliness in our FARs.

This is a common misinterpretation, arising from casual or imprecise language. In normal conversation, we use "type" to mean "kind" or "sort." In that sense, a skydiving main canopy is usually worn on the back, so it is a kind of back parachute; a base canopy is usually worn on the back, so it is a kind of back parachute; and so on.

However, for the FAA, "type" has a specific meaning. It is short for "approved type," one manufactured under a type certificate, or under a TSO, or a personnel-carrying military parachute . For the FAA, a main parachute is not "typed.". A main parachute is not a back, seat, or chest "type."

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Consider this - if you are a rigger who holds ONLY a chest rating, I do not believe you can legally pack a back pack main parachute for another person, because you do not hold a back rating. And we are only supposed to pack parachute for other people when we have the correct type rating.l

14 CFR 65.125(c) specifically exempts us from having to comply with 65.129(a)(the requirement for a type rating) when we pack, maintain, or alter a main parachute. 65.125(c) allows a certificated rigger, without regard to type rating, to pack a main. A chest-only senior rigger may certainly pack a main canopy for someone else to use.

Mark

Damn! You are good.

I was going to try to mention that "Certificate Required" is in 65.111, which is not one of the excluded paragraphs.

But closer reading of 65.111 says you need a certificate, and makes no mention of a type rating.

Tricky tricky tricky.

By the way, I want to add that I don't mean to make a big argument. This discussion is fun, and picking apart the language is not always easy. I mostly try to figure it out because I feel that it is essential to understand what laws you are breaking, should you decide that breaking them is what you will do.
Thanks, Mark, for your incredible precision. It is clear I will never be an aviation lawyer.

-paul

[NovaTTT 2]

Nevermind.

"Even in a world where perfection is unattainable, there's still a difference between excellence and mediocrity." Gary73

[rapaz 0]

Tanks a lot everybody, very nice ammount of info and stuff.

But still hard for me to understand something: for a senior rigger who wants to be a master and needs the two ratings, the seat or chest practically doesnt exist in the skydiving sport world, the seats probably has a few models for pilots?, and the chest are mostly the military, so if I want to be a master to perform skydiving stuff, I need to find a few pilots and pack their rigs or go into some headquarter to pack the 80 more necesary for the master rigger ticket.

[riggerpaul 1]

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Tanks a lot everybody, very nice ammount of info and stuff.

But still hard for me to understand something: for a senior rigger who wants to be a master and needs the two ratings, the seat or chest practically doesnt exist in the skydiving sport world, the seats probably has a few models for pilots?, and the chest are mostly the military, so if I want to be a master to perform skydiving stuff, I need to find a few pilots and pack their rigs or go into some headquarter to pack the 80 more necesary for the master rigger ticket.

That's a lot of the reason I am still a "Senior"

I just cannot see doing 100 chest repacks, when I will essentially never see a chest reserve again.

Maybe it is supposed to be considered a rite of passage, and my not wanting to do them makes me unworthy. But to me, it just sounds nuts.

I have had discussions with at least one person who says that the 2 types thing was likely to be removed in a rewrite of the rigging stuff in Part 65. But that rewrite never came, so here we are.

[masterrigger1 2]

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That is the current interpretation of a very few riggers, including a DPRE or two. It is not the current interpretation of the FAA as a whole, although some FSDOs have been convinced by local riggers to interpret the regulation that way.

The rule (not interpretation) has been written as it stands now for many years. It was not changed in 2001.

That rule, 65.111 paragragh (a) can be read in the very early versions of poynter's in it's original version.
That would be well before the 2001 "re-write".

The regulation was written with the same intent as the one for IA's. We, the skydiving and rigging community, never read the rule for what it really meant.
I too, was quilty until this was pointed out to me very vividly by the FAA a few years back.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mark 107]

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But still hard for me to understand something: for a senior rigger who wants to be a master and needs the two ratings, the seat or chest practically doesnt exist in the skydiving sport world, the seats probably has a few models for pilots?, and the chest are mostly the military, so if I want to be a master to perform skydiving stuff, I need to find a few pilots and pack their rigs or go into some headquarter to pack the 80 more necesary for the master rigger ticket.

Yup. Since 1984 I have packed exactly 2 chest type parachutes for use, and neither one was deployed. If you are a civilian, your best course of action is to add a seat rating to your senior rigger certificate. After you have your seat rating, you can pack without supervision. If a pilot rig does not have space to record the number of packs (the way a PD reserve does), then pack it 5 or 10 times whenever it comes in for repack.

Mark

[riggerpaul 1]

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That is the current interpretation of a very few riggers, including a DPRE or two. It is not the current interpretation of the FAA as a whole, although some FSDOs have been convinced by local riggers to interpret the regulation that way.

The rule (not interpretation) has been written as it stands now for many years. It was not changed in 2001.

That rule, 65.111 paragragh (a) can be read in the very early versions of poynter's in it's original version.
That would be well before the 2001 "re-write".

The regulation was written with the same intent as the one for IA's. We, the skydiving and rigging community, never read the rule for what it really meant.
I too, was quilty until this was pointed out to me very vividly by the FAA a few years back.

Cheers,
MEL

Yes, 65.111 has not changed much. In 2001 they added stuff relating to tandem parachutes.

But 65.125 is where it says what type of supervision a rigger may provide. And in the earlier 65.125 there was no mention of anything in Part 105. If only said that a rigger could supervise any work that was a privilege of his certificate and type rating.

When a mechanic supervises and apprentice, it means that the mechanic takes the responsibility for the work on his certificate, even though the apprentice did the work. The work is not re-done.

That being the precedent, when a rigger supervises a student rigger, the certified rigger is allowed to take responsibility for the work on his certificate, even though the student did the work. Why should the work be re-done?

The restriction on supervising relating only to main parachutes seems to have come with the poor wording in the change of 65.125 in 2001, where it refers to paragraphs in Part 105 that speak only of main parachutes.

Regarding IAs, isn't it still the case that an owner can assist the IA in his aircraft's annual inspection? That is, the IA supervises the owner, and the work is covered by the IA's certificate. Again, when supervised by an appropriately rated person, the work is not re-done.

What different intent did the FAA tell you about? Because it would all seem to hinge on that.

Thanks for any clarification.

-paul

[faulknerwn 38]

If you want your Masters you might try doing seat packs. We get those coming in pretty regularly to our loft from pilots. Do them a few times each one comes in and you will have your packs..

[riggerpaul 1]

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If you want your Masters you might try doing seat packs. We get those coming in pretty regularly to our loft from pilots. Do them a few times each one comes in and you will have your packs..

Thanks for the tip. I'll keep that in mind. I don't think we've seen many seats in the loft at my home dz, but I'll talk with the master there to see if this is an opportunity for my.

I am not too fond of the notion that we would pack a rig many times, essentially for our own convenience. If the packing is really the source of much of the wear and tear on the system, then we are essentially stealing some of the life of the equipment from the rightful owner. Or do you think I might be too ethical in this?

Besides, if MEL is correct about the supervised work not being allowed into the air, the work must be redone after I do whatever I do.

All in all, it is a sub-optimal situation.

[NovaTTT 2]

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Besides, if MEL is correct about the supervised work not being allowed into the air, the work must be redone after I do whatever I do.

If you have a seat (or chest) rating, you will self-supervise.

"Even in a world where perfection is unattainable, there's still a difference between excellence and mediocrity." Gary73

[jenkincb00 0]

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But still hard for me to understand something: for a senior rigger who wants to be a master and needs the two ratings, the seat or chest practically doesnt exist in the skydiving sport world, the seats probably has a few models for pilots?, and the chest are mostly the military, so if I want to be a master to perform skydiving stuff, I need to find a few pilots and pack their rigs or go into some headquarter to pack the 80 more necesary for the master rigger ticket.

Yup. Since 1984 I have packed exactly 2 chest type parachutes for use, and neither one was deployed. If you are a civilian, your best course of action is to add a seat rating to your senior rigger certificate. After you have your seat rating, you can pack without supervision. If a pilot rig does not have space to record the number of packs (the way a PD reserve does), then pack it 5 or 10 times whenever it comes in for repack.

Mark

you wouldn't be my rigger if you packed my rig 5 or 10 times when it came in, wear your own shit out!

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