Lead Seal Clarification Notice

[masterrigger1 2]

For the guys placing other than lead seals after a pack job, you might want to look at this.

Also note the clarification of when a seal is to be placed on a parachute.

Is is after "packing" a parachute, with no mention of AAD maintenance...

Looks pretty solid to me!

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[pchapman 280]

Well, at least there's a clarification by the FAA, something we never get in most rigging discussions where we argue about what the rules allow or don't.

It does open up the possibility of changing how seal are done, by working at a different level -- if the PIA can be convinced of a workable non-lead system, then manufacturers probably would come on board and approve it, and in turn the FAA might accept it if the industry accepts a new way.

Still, the FAA ruling is a little vague on logic.

They make the point that riggers get a seal press to seal things, so it sort of makes sense that riggers are to use that seal press.

But that doesn't specifically say anything about clamping that press down on a lead disk. One is left to infer that manufacturer's manuals and 8083-17 tend to talk about lead and not paper, and with little or no info out there about paper, the default is the traditional lead seal.

[councilman24 37]

Yep, means that after AAD maintenance you don't have to seal it! We can all read it as we would like.

Seriously, this doesn't have anything to do with the AAD maintenance resealing issue. It's saying when a seal is needed it has to be lead.

It ignores the fact that a press can impress a symbol on a flexible, printable plastic seal as well as a plastic round seal that mimics a lead seal. Ted Strong, shortly before he died, was very happy to see the plastic seal that works as I demonstrated at the last PIA meeting. He needed it for rigs packed at the factory for shipment to Europe. Ted was also going home to use the plastic seal and perhaps put the flexible seal in his manuals. The interpretation that I had from Carol Giles simply said that unless in a manual the PRH as written should be followed.

This FAA notice also is in conflict with a long standing interpretation that had been applied to parachutes but that I haven't seen in writing. The reason, or one reason, that the FAA had been refusing to issue Airworthiness Directives on parachutes was that they were NOT "an aircraft, engine, propeller, or appliance" and thus were not eligible for an AD.

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

[tdog 0]

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then manufacturers probably would come on board and approve it, and in turn the FAA might accept it if the industry accepts a new way.

I think actually, if the manufacture simply put paper seals it in the instructions, then it would be A-OK for the FAA per the logic process laid out in item 4.

4. B. says: (a rigger) shall use the methods, techniques, and practices prescribed in the current manufacturer’s maintenance manual

4. C. says: (a rigger shall) seal the pack with his seal in accordance with the manufacturer’s recommendation for that type of parachute

4. D. says: When the manufacturer has not provided concise guidance, the Administrator provides guidance in FAA-H-8083-17, Parachute Rigger Handbook, as an acceptable method of sealing the parachute.


I am surprised that item 5 "Action" is conflicting with the logic laid out in 4... 5 says that lead seals must be used, but gives no provisions for when a manufacture gives conflicting guidance as per 4B and 4C.

Thus, if a manufacture provided "concise guidance" that bubble gum was an appropriate seal, it would overrule the "Administrator's guidance", as the logic in 4 puts the manufacture as the first source for info, the handbook as the 2nd when the first is silent.

[councilman24 37]

And I have another manufacturer that is considering putting a flexible seal (I've stopped saying paper because paper really isn't appropriate) in their manual.

And as I said the ones that are plastic film in nature can take an impression from a seal press with a rubber backing in the press when used.

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

[JerryBaumchen 1,468]

Hi Terry,

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And I have another manufacturer that is considering putting a flexible seal (I've stopped saying paper because paper really isn't appropriate) in their manual.

And I have been asking the Chairman of the PIA Rigging Committee to come up with a PIA-approved wording so that all mfrs can use a common wording.

The strength is in presenting a united front.

JerryBaumchen

[masterrigger1 2]

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Yep, means that after AAD maintenance you don't have to seal it! We can all read it as we would like.

Terry,
If you happen to have noticed (or not), the document is really intended for inspectors and their inspection/surveillance process.

It basically spells out that they are aware of some riggers using "other" types of seals.

It also spells out that unless you are from a foreign country that has a documented paper or other seal program, it would be illegal in this country.


The other part is that the only avenue listed in this document for sealing a parachute is after packing it.

Just for reference, here are some cold hard facts:

1. There have been fatalities directly related to opening and closing cointainers after performing AAD maintenance.

2. There are no instructions from either the H/C manufacturer OR the AAD manufacturer to show someone the process for performing the required steps of maintenance.

3.There are lawsuits pending in some of the above cases.

4. There are legal types looking for Subject Matter Experts to testify in court regarding the above.
...and no I am not!

5. The military will NOT close a H/C unless the balance of equipment has vaid service life for the entire pack cycle.

So for me , I am going to stick with the military version, sit on the side lines and watch the fireworks.

BS,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[councilman24 37]

Since my inspector sent it to me I did know it was intended as guidance for inspectors.

Do you really think who ever authored it had in their mind opening the container and resealing for other maintenance? We can leave AAD maintenance out of it and call it general minor maintenance. Opening a rig to shorten a loop that has slipped would involve many of the same functions.

So, your keying on the word packing because you believe that if the seal is broken it should be completely reinspected and packed. I take no issue with that as your personal position. I won't open someone elses work and put my seal on it without doing that also.

In the notice, section 4b says "When packing the parachute, the parachute rigger is performing maintenance on a Technical Standard Order (TSO) product that falls under 14 CFR part 43....." This paragraph is quoting the authority by which the rest of the regs and manufacturers instructions apply to these activities. I don't take this as meaning only packing is allowed. Again, last I knew in other situations the weren't calling a parachute an appliance but we know they have authority over parachutes.

The next occurrence of "packing" in the notice is 4c which is just a restatement of Title 14 CFR part 65, § 65.133. Nothing new here.

That's the only two times "packing" occurs in the document.

The guidance to ASI's "...ASIs should understand that § 65.133 is interpreted as meaning that the certificated parachute rigger must seal the parachute with a lead-type seal. Paper seals are not authorized to be used by certificated parachute riggers. ...." is opining that because only a lead seal is shown in the PRH (for now) that only a lead seal is allowed under 65.133.

But, 4d contains the standard caveat "When the manufacturer has not provided concise guidance, the Administrator provides guidance in FAA-H-8083-17, Parachute Rigger Handbook, as an acceptable method of sealing the parachute." (emphasis added)

So, nothing new here over the Carol Giles letter to PIA rigging committee to me. It's just making the ASI's aware of this interpretation. And eliminating plastic seals by quoting lead so much.


As to whether a rig should be opened and resealed by another rigger, I don't believe it should be. Whether the regs say that or not is debatable. (as shown above) As to whether a rigger should open and close a rig they packed without completely repacking, I believe that's their choice. They have all of the responsibility for their own work. I don't see anything in the regs that prevents it.

And the lawyers called me too. (no I'm not either)

You coming to Daytona Beach next month?

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

[masterrigger1 2]

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Do you really think who ever authored it had in their mind opening the container and resealing for other maintenance? We can leave AAD maintenance out of it and call it general minor maintenance. Opening a rig to shorten a loop that has slipped would involve many of the same functions.

Terry, They purposedly left maintenance and AAD language out of the text for legal reasons.

Remember when I asked AFS-100 for some interps about AAD's and they would not give them out because they (AADs) were not a TSO'd device???

The seal is there to prevent tampering and also to identify the rigger that packed the parachute. That is the FAA's definition,..not mine.
So if the seal gets broken to fix the closing loop that should have been fixed before it was sealed the first time, ...yes I think the regs spell out a new pack job!

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...is opining that because only a lead seal is shown in the PRH (for now).....

Well from what I hear the PRH is being re-written as we speak. I do not think the regs are going to change before it is to be written/published.

In other words if you are going to change something, right now might just be too late!

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So, nothing new here over the Carol Giles letter to PIA rigging committee to me. It's just making the ASI's aware of this interpretation. And eliminating plastic seals by quoting lead so much.

I guess I missed that. I have no idea who Carol Giles is or what the letter to you was in reference to.

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As to whether a rig should be opened and resealed by another rigger, I don't believe it should be. Whether the regs say that or not is debatable.

As you know we are still waiting on that interp also.

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As to whether a rigger should open and close a rig they packed without completely repacking, I believe that's their choice. They have all of the responsibility for their own work. I don't see anything in the regs that prevents it.

We have that interp already. Just be clear, that is a big "NO".

Caleb Glick in AFS-350 can guide you though that if needed.

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You coming to Daytona Beach next month?

Yep, Dave and I will be there spicing up the event!
Be good and I might even buy you a beer!

MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[mjosparky 4]

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Looks pretty solid to me!

It is just another example of FFA speak. They have quoted several CFR’s none of which support their position. Although the PRH shows a picture of a lead seal it make no mention of one in the text.
Sparky

My idea of a fair fight is clubbing baby seals