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airtime1

Privileges of an "almost" rigger

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I witnessed a cut-a-way at a DZ I don't jump at recently and over heard an individual state that it was his 8th save. Having been a rigger in the area for many years I instinctively asked how long he'd been a rigger. Response: "I have 40 packs but I haven't taken the test." Then I heard him state that he was owed a bottle for the reserve ride.

Have I lived an isolated skydiving existence, believing that 8 saves out of 40 packs is a fantastic percentage but strongly suggests questionable main packing techniques being taught? Am I naive in the belief that a rigger would want to assist in correcting the bad main packing techniques at the DZ to cut down on the malfunction rate?

Should I be put out to pasture because I believe that to be "owed a bottle" one should not only pack but learn basic sewing tech., study, and pass a written and practical test?

At the very least should I admit my ignorance by not having a packer boy to do the work while I put my seal on it and collect the money and call it training?

If necessay I'll admit that I'm simply jealous having over 400 reserve packs and only 5 saves.
Actually, I do thank God for my percentages.

RobH

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One thing I've found is newies like that are probly just full of crap. They tend to grossly pad their saves or just outright lie thinking that 1 out of every 5 re-packs getting used is the norm. My question to him would be "who is he packing under and why has he let him go 40 pack jobs without getting his ticket?"

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I see this and alarm bells go off in my Head. Far 65 makes it clear that a Rigger CAN supervise a candidate for his required packjobs - but FAR 105 states that unless you have the ticket in your hand - your reserve packjob CANNOT be jumped. This was hammered into my head by a DPRE during my practical exam. Unless I read this thread wrong, a major no-no has taken place.

Can somebody clear this up?
=========Shaun ==========


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I see this and alarm bells go off in my Head. Far 65 makes it clear that a Rigger CAN supervise a candidate for his required packjobs - but FAR 105 states that unless you have the ticket in your hand - your reserve packjob CANNOT be jumped. This was hammered into my head by a DPRE during my practical exam. Unless I read this thread wrong, a major no-no has taken place.

Can somebody clear this up?



Point out the text in FAR 105, Parachute Operations, that says that? I can't find it.

Part 65 sub part F covers Certification of Riggers

Sec. 65.125 Certificates: Privileges.

(a) A certificated senior parachute rigger may--
(1) Pack or maintain (except for major repair) any type of parachute
for which he is rated; and
(2) Supervise other persons in packing any type of parachute for
which that person is rated in accordance with Sec. 105.43(a) or
Sec. 105.45(b)(1) of this chapter.



Seems pretty clear to me.
:)
"Buttons aren't toys." - Trillian
Ken

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Point out the text in FAR 105, Parachute Operations, that says that? I can't find it.

14 CFR Section 105 Subpart C

105.43 Use of single-harness, dual-parachute systems.
top

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 120 days before the date of its use of a certificated parachute rigger, the person making the next jump with that parachute, or a non-certificated person under the direct supervision of a certification parachute rigger.

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

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Interesting interpertation. I have had a former DPRE and multiple master riggers supervise me and their interpertation of FAR 105 was that it had to be signed off and sealed by the rigger that supervised but it did not render a pack job as invalid just since it was done by someone with out their own ticket.
Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

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Interesting interpertation. I have had a former DPRE and multiple master riggers supervise me and their interpertation of FAR 105 was that it had to be signed off and sealed by the rigger that supervised but it did not render a pack job as invalid just since it was done by someone with out their own ticket.



Not really. The rule says "must have been packed by a certificated parachute rigger". It doesn't give an option for supervising a non-certificated rigger. Sort of like an Annual Inspection on an aircraft. It has to be done by an IA, not accomp;lished by an A&P under the supervision of an IA.

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In Reply To
--------------------------------------------------------------------------------


Interesting interpertation. I have had a former DPRE and multiple master riggers supervise me and their interpertation of FAR 105 was that it had to be signed off and sealed by the rigger that supervised ....



That's is correct!
A surpervising rigger has to sign and seal the parachute with his seal symbol and name.



Not really. The rule says "must have been packed by a certificated parachute rigger". It doesn't give an option for supervising a non-certificated rigger.

Quote


Absolutely Not True!
If it were, which it is not, the letter for the required pack jobs could never be acheived.

It is required that a canidate for a rigger's certificate pack at least 20 reserve pack jobs prior to taking the written.

If a DPRE told you that, he needs some re-training!

Part 65 list the certification neccesary for packing parachutes, both mains and certificated types.
It is vivid in it's writting there, also in the rule of Part 105, in AC 105-2C, and also in the DPRE and Inspector's handbook.


If there is any further question on this matter, please let me know.

This type of mis-information needs to end here.

Cheers,
MEL

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Absolutely Not True!
If it were, which it is not, the letter for the required pack jobs could never be acheived.

It is required that a canidate for a rigger's certificate pack at least 20 reserve pack jobs prior to taking the written.

If a DPRE told you that, he needs some re-training!

Part 65 list the certification neccesary for packing parachutes, both mains and certificated types.
It is vivid in it's writting there, also in the rule of Part 105, in AC 105-2C, and also in the DPRE and Inspector's handbook.


If there is any further question on this matter, please let me know.

This type of mis-information needs to end here.

Cheers,
MEL



I'm not understanding this...how is that not true? The FAR says that the reserve has to be packed by a CERTIFICATED rigger... how is a trainee a certificated rigger if they haven't tested and gotten their seal yet?
Mike
I love you, Shannon and Jim.
POPS 9708 , SCR 14706

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Absolutely Not True!
If it were, which it is not, the letter for the required pack jobs could never be acheived.

It is required that a canidate for a rigger's certificate pack at least 20 reserve pack jobs prior to taking the written.



I'm not a rigger. I'm just an average shmo trying to make sense of this. But, theoretically, wouldn't it be possible for a person going for their ticket to pack a reserve while being supervised by a rigger, then have the rigger unpack it and repack it? After all, the reqs say that the "student" must pack 20 reserves, but they don't say that those packs actually have to be jumped.

I'm not saying this is feasible, but wouldn't it satisfy the two seemingly incongruous requirements?

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Absolutely Not True!
If it were, which it is not, the letter for the required pack jobs could never be acheived.

It is required that a canidate for a rigger's certificate pack at least 20 reserve pack jobs prior to taking the written.

Ummm Mark?. It is absolutely true. The rule says what it says. To make a legal jump per 14CFR Section 105 your reserve SHALL be packed by a certificated rigger. The pack jobs that are done under supervision of a rigger to qualify for their rigger's ticket are not legal to be jumped.

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I'm not a rigger. I'm just an average shmo trying to make sense of this. But, theoretically, wouldn't it be possible for a person going for their ticket to pack a reserve while being supervised by a rigger, then have the rigger unpack it and repack it? After all, the reqs say that the "student" must pack 20 reserves, but they don't say that those packs actually have to be jumped.

I'm not saying this is feasible, but wouldn't it satisfy the two seemingly incongruous requirements?



It's very feasible and that is the intent of the rule. Pack em and unpack em, and pack em again...just don't jump em cause they weren't packed by a senior or master rigger.

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***
Ummm Mark?. It is absolutely true. The rule says what it says. To make a legal jump per 14CFR Section 105 your reserve SHALL be packed by a certificated rigger. The pack jobs that are done under supervision of a rigger to qualify for their rigger's ticket are not legal to be jumped.
Quote


Again, You need to look at FAR 65, not Part 105.

And again it is not true!
The pack jobs that are packed under supervision,sealed,and signed are very legal.

PM Sent.
Cheers,
MEL
FAA DPRE

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Quote


Ummm Mark?. It is absolutely true. The rule says what it says. To make a legal jump per 14CFR Section 105 your reserve SHALL be packed by a certificated rigger. The pack jobs that are done under supervision of a rigger to qualify for their rigger's ticket are not legal to be jumped.

Quote


Again, You need to look at FAR 65, not Part 105.

And again it is not true!
The pack jobs that are packed under supervision,sealed,and signed are very legal.

PM Sent.
Cheers,
MEL
FAA DPRE



Mel - for personal curiosity, could you post what section of 65 you're getting your proof from? The only part I saw that was anywhere near applicable was this:

***Sec. 65.111 Certificate required.

(a) No person may pack, maintain, or alter any personnel-carrying
parachute intended for emergency use in connection with civil aircraft
of the United States (including the reserve parachute of a dual
parachute system to be used for intentional parachute jumping) unless
that person holds an appropriate current certificate and type rating
issued under this subpart and complies with Secs. 65.127 through 65.133.


Mike
I love you, Shannon and Jim.
POPS 9708 , SCR 14706

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§ 65.111 Certificate required.
top
(a) No person may pack, maintain, or alter any personnel-carrying parachute intended for emergency use in connection with civil aircraft of the United States (including the reserve parachute of a dual parachute system to be used for intentional parachute jumping) unless that person holds an appropriate current certificate and type rating issued under this subpart and complies with §§65.127 through 65.133.

(b) No person may pack, maintain, or alter any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person—

(1) Has an appropriate current certificate issued under this subpart;

(2) Is under the supervision of a current certificated parachute rigger;

(3) Is the person making the next parachute jump with that parachute in accordance with §105.43(a) of this chapter; or

(4) Is the parachutist in command making the next parachute jump with that parachute in a tandem parachute operation conducted under §105.45(b)(1) of this chapter.

(c) Each person who holds a parachute rigger certificate shall present it for inspection upon the request of the Administrator or an authorized representative of the National Transportation Safety Board, or of any Federal, State, or local law enforcement officer.

(d) The following parachute rigger certificates are issued under this part:

(1) Senior parachute rigger.

(2) Master parachute rigger.

(e) Sections 65.127 through 65.133 do not apply to parachutes packed, maintained, or altered for the use of the armed forces.

[Doc. No. 1179, 27 FR 7973, Aug. 10, 1962, as amended by Amdt. 65–9, 31 FR 13524, Oct. 20, 1966; 32 FR 5769, Apr. 11, 1967; Amdt. 65–42, 66 FR 23553, May 9, 2001]

§ 65.113 Eligibility requirements: General.
top
(a) To be eligible for a parachute rigger certificate, a person must—

(1) Be at least 18 years of age;

(2) Be able to read, write, speak, and understand the English language, or, in the case of a citizen of Puerto Rico, or a person who is employed outside of the United States by a U.S. air carrier, and who does not meet this requirement, be issued a certificate that is valid only in Puerto Rico or while he is employed outside of the United States by that air carrier, as the case may be; and

(3) Comply with the sections of this subpart that apply to the certificate and type rating he seeks.

(b) Except for a master parachute rigger certificate, a parachute rigger certificate that was issued before, and was valid on, October 31, 1962, is equal to a senior parachute rigger certificate, and may be exchanged for such a corresponding certificate.

§ 65.115 Senior parachute rigger certificate: Experience, knowledge, and skill requirements.
top
Except as provided in §65.117, an applicant for a senior parachute rigger certificate must—

(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;

(b) Pass a written test, with respect to parachutes in common use, on—

(1) Their construction, packing, and maintenance;

(2) The manufacturer's instructions;

(3) The regulations of this subpart; and

(c) Pass an oral and practical test showing his ability to pack and maintain at least one type of parachute in common use, appropriate to the type rating he seeks.

[Doc. No. 10468, 37 FR 13251, July 6, 1972]

also:
§ 65.127 Facilities and equipment.
top
No certificated parachute rigger may exercise the privileges of his certificate unless he has at least the following facilities and equipment available to him:

(a) A smooth top table at least three feet wide by 40 feet long.

(b) Suitable housing that is adequately heated, lighted, and ventilated for drying and airing parachutes.

(c) Enough packing tools and other equipment to pack and maintain the types of parachutes that he services.

(d) Adequate housing facilities to perform his duties and to protect his tools and equipment.

[Doc. No. 1179, 27 FR 7973, Aug. 10, 1962, as amended by Amdt. 65–27, 47 FR 13316, Mar. 29, 1982]

§ 65.129 Performance standards.
top
No certificated parachute rigger may—

(a) Pack, maintain, or alter any parachute unless he is rated for that type;

(b) Pack a parachute that is not safe for emergency use;

(c) Pack a parachute that has not been thoroughly dried and aired;

(d) Alter a parachute in a manner that is not specifically authorized by the Administrator or the manufacturer;

(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute; or

(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has—

(1) Performed duties under his certificate for at least 90 days within the preceding 12 months; or

(2) Shown the Administrator that he is able to perform those duties.

§ 65.131 Records.
top
(a) 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—

(1) Its type and make;

(2) Its serial number;

(3) The name and address of its owner;

(4) The kind and extent of the work performed;

(5) The date when and place where the work was performed; and

(6) The results of any drop tests made with it.

(b) Each person who makes a record under paragraph (a) of this section shall keep it for at least 2 years after the date it is made.

(c) Each certificated parachute rigger who packs a parachute shall write, on the parachute packing record attached to the parachute, the date and place of the packing and a notation of any defects he finds on inspection. He shall sign that record with his name and the number of his certificate.

§ 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.


It is also listed in several other documents.
Search and ye shall find!

Cheers,
MEL
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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I see this and alarm bells go off in my Head. Far 65 makes it clear that a Rigger CAN supervise a candidate for his required packjobs - but FAR 105 states that unless you have the ticket in your hand - your reserve packjob CANNOT be jumped. This was hammered into my head by a DPRE during my practical exam. Unless I read this thread wrong, a major no-no has taken place.

Can somebody clear this up?



Gosh, talk about obscure readings of the regulations!

I’m not a lawyer or DPRE, but I spent a great deal of time sorting through regulatory changes and offering comments to the FAA about those changes.

I’ll offer my view and stake out a position that says a person under the supervision of a rigger has ‘always’ been able to pack a reserve parachute, but until a 2001 regulatory change, that person was unable to pack a main parachute. Part of the regulatory change to parts 65 and 105 was to eliminate this inconsistency and allow a rigger to supervise a main pack job, just as he was already authorized to supervise a reserve pack job.

I’ll agree that the language in parts 65.111 and 65.125 appears to be inconsistent, but a historical reading of the regulation, and a review of the FAA intent as defined in the original NPRM and final rule with comments, makes it clear that an FAA certificated rigger CAN supervise the packing of a reserve parachute.

The original proposal to alter parts 65 and 105 is available in the Federal Register here: http://frwebgate.access.gpo.gov/cgi-bin/getpage.cgi?position=all&page=18302&dbname=1999_register

Comments and the final rule are available here: http://frwebgate.access.gpo.gov/cgi-bin/getpage.cgi?dbname=2001_register&position=all&page=23543
Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

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Tom,
The part 65 reg says "pack, maintain, or alter". The part 105 reg says "conduct a parachute operation". I agree that the intent may have been for riggers in training to pack reserves under the supervision of a certificated rigger, and then for those reserves to be jumped. But, somewhere along the line, the 105 reg was codified to say what it does.
I'm just trying to help make sure someone doesn't misinterpret and get themselves in trouble.

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>The part 65 reg says "pack, maintain, or alter."

While going over FAR's can be fun and sometimes illuminating, in most cases a re-reading of the FAR's will not cause a change in a procedure that's been in common usage for decades. If we read the FAR's literally, we'd have to radically change the way we jump, rig and pack for no good reason.

Keep in mind that in most cases the process is not:

1) a genius writes the FAR
2) skydivers/riggers/gear manufacturers read the new FAR and alter how they do things
3) skydiving changes as a result

The process is:

1) a genius comes up with new gear/training systems/rigging techniques
2) skydivers/riggers/gear manufacters change how they do things
3) skydiving changes as a result
4) someone updates the FAR's

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Wow!
Does this mean that dozens of my customers - and hundreds of students - have jumped illegally-packed reserves?

I always interpreted the FAR to mean that if the work was good enough for a licensed rigger to sign - over the work of an apprentice - then it was legal to jump.

However, I also believe that if an apprentice rigger has packed 40 plus reserves - but not been tested by a Rigger Examiner - then something is wrong.

Rob Warner
FAA Master Rigger
Canadian Rigger Instructor

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However, I also believe that if an apprentice rigger has packed 40 plus reserves - but not been tested by a Rigger Examiner - then something is wrong.



I had roughly 65 packjobs and 3 saves before I got someplace I could be tested.
Miami

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Thanks, Mel - but I'm still not tracking your logic. Per 105.43, only a CERTIFICATED rigger can pack a skydiving reserve.

I'm not seeing where a trainee can LEGALLY pack a skydiving reserve in any of this, because they don't yet have their certificate. Can you point me (specifically) to what I'm missing?
Mike
I love you, Shannon and Jim.
POPS 9708 , SCR 14706

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Thanks, Mel - but I'm still not tracking your logic. Per 105.43, only a CERTIFICATED rigger can pack a skydiving reserve.

I'm not seeing where a trainee can LEGALLY pack a skydiving reserve in any of this, because they don't yet have their certificate. Can you point me (specifically) to what I'm missing?



Just throwing something out there.... If the rigger is supervising step by step (in the room, actively working with the apprentice) - the rigger's eyes inspect every step while the students hands do the work. A rigger's eyes and brain is what you hire a rigger for, if they direct someone else's hands to do the folding, it is no different than directing their own hands...

How many seconds can a reserve be touched by a non-rigger before it becomes illegeally packed?

Heck, translate this to other industries where apprentices work under teachers. In medicine students start by watching a procedure, at sometime they start to help the teacher with the surgery, and by the end of their apprentice period they are supposed to be able to direct the whole operating room and be in command of the procedure, perhaps teaching the next generation, with their teacher stepping back and watching. (watch once, do once, teach once) If it works for my heart, then it seems a reserve...:P

I think there is a difference between the rigger not paying attention and signing off when done (if a reputable rigger is that comfortable with their student it is time to get them signed off), and the rigger's eyes and soul being on the packjob while someone else does the fabric folding.

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Just throwing something out there.... If the rigger is supervising step by step (in the room, actively working with the apprentice) - the rigger's eyes inspect every step while the students hands do the work. A rigger's eyes and brain is what you hire a rigger for, if they direct someone else's hands to do the folding, it is no different than directing their own hands...

How many seconds can a reserve be touched by a non-rigger before it becomes illegeally packed?

Heck, translate this to other industries where apprentices work under teachers. In medicine students start by watching a procedure, at sometime they start to help the teacher with the surgery, and by the end of their apprentice period they are supposed to be able to direct the whole operating room and be in command of the procedure, perhaps teaching the next generation, with their teacher stepping back and watching. (watch once, do once, teach once) If it works for my heart, then it seems a reserve...:P

I think there is a difference between the rigger not paying attention and signing off when done (if a reputable rigger is that comfortable with their student it is time to get them signed off), and the rigger's eyes and soul being on the packjob while someone else does the fabric folding.



Tdog - I don't disagree that perhaps it _should_ be okay. I'm just pointing out that the rule doesn't offer that option. It says what it says. Maybe it's time for USPA to talk to Washington about issuing clarification or changing the Part 105 rule.
Blues,
ht

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