Rigging Question

[polarbear 1]

I am just about ready to take my riggers exams, but I have a question that I am having trouble getting a definite answer to. Knowledgeable people, please help!
Simply put, the question is: Who can assemble a canopy to a container? The rigger I am under was asked this question on his practical, and the DPRE told him that assembling a ram-air canopy to a container counts as an alteration and thus requires a Master rigger (for either main or reserves). It does make sense that assembling a canopy can affect the airworthyness of the system, which defines major repairs/alterations.
However, nowhere in the FARs do I find anything that reinforces this. In fact, AC 105-2C says that the owner of a parachute system can assemble/disassemble components for storage or shipping purposes if the operations required are simple (installing slinks/rapide links seems pretty simple to me).
In addition, a senior rigger can pack a ram-air; when he packs it, he puts his name on the card certifying the ENTIRE rig as airworthy. Part of inspecting/packing the rig is doing a line check and making sure the links are correctly attached...if a senior rigger can do this (and thus verify it has been attached correctly), why wouldn't he be able to assemble the canopies?
Finally, all of the owner's manuals I have seen have called for just a rigger to assemble, not a Master rigger.
So, how 'bout it?

[Hooknswoop 19]

From Pointer's:
AC 105-2
"The assembly or mating of approved parachute components from different manufactures may be made by a certificated and appropiately rated rigger or parachute loft in accordance with the manufacture's instructions and without further authorization by the manufacture or the FAA."
Hook

[AndyMan 7]

Wow. I know tons of jumpers who swap out their own mains. I had no idea this requried a rigger to do. Am I alone here?
Would this go so far as to swap a main complete with risers? What about detaching the three rings to exercise them? Doesn't this qualify as dissasemply and reassembly?
_Am (confused)
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[SkydiveMonkey 0]

Is that the same as in the UK?
boobies - the cause of, and solution to, all of lifes problems

[BadDog 0]

My understanding is that anyone can do whatever they want with a main, but only a rigger with the appropriate rating (back, chest, seat, lap) can assemble the rest of the system (container, reserve, AAD).
CorporateLawyerDave aka BadDog

[Hooknswoop 19]

The key word is "approved" components. Just the TSO'd stuff. Anyone can assemble a main from the risers up.
Hook

[polarbear 1]

With regard to your quote from AC 105 2C, that's what I think. It's just that my supervising rigger specifically got asked this on his practical, and got it wrong; the DPRE (who is a highly experienced rigger and an FAA official) said that the FAA considers assembly as an alteration and thus requires a master rigger.

Quote

The key word is "approved" components. Just the TSO'd stuff. Anyone can assemble a main from the risers up.

Not if it is considered an alteration...alterations require master riggers, period. Alterations to TSO'd components require further authorization from a manufacturer/FAA.
To reword my original question, does anybody know for sure if the FAA considers assembling a canopy as an alteration? This seems really weird, but the DPRE ought to know what he is talking about...

[billvon 3,090]

>To reword my original question, does anybody know for sure if the FAA
>considers assembling a canopy as an alteration? This seems really weird, but
> the DPRE ought to know what he is talking about...
Keep in mind that parachuting is not heavily regulated; there are not a lot of FAA experts who can interpret the parachuting FAR's. Several gear manufacturers have long stories about how different FAA employees interpreted the regulations in different ways. Indeed, in many cases, it is the gear manufacturers themselves who come up with the rules that are later codified into law, primarily because it is they, not the FAA, who understand the technology.
-bill von

[alan 1]

I agree with bill on this. We went thru a similar situation a few years back when someone in the FAA decided that installing a CYPRES in a new rig was a major modification. After going thru the system, it finally decided that "assembly" of a CYPRES in a rig designed to accpet it (CYPRES ready) was OK under AC 105 and could be done by a senior rigger. I don't think "assembly" is a "modification" by definition. Unfortunately, as bill has pointed out, the FAA grants considerable latitude to its' field representatives in interpretation of the FARs and this often leads to inconsistentcies in the application of the FARs. Why not discuss it with the DPRE in an open and non-confrontational way? You could refer to the CYPRES case/ruling to support the case that assembly of components that the system was designed to accept is not a major modification. The precedent has been established and the DPRE may not be aware of it.
alan

[MrHixxx 0]

When I tested, assembly was not considered an alteration. Anytime I inspect a system, I loosen and retighten the links to ensure they are correct and do a continuity check. This is essentially the same as assembly, barring putting the links on the risers...
-Jon
"Sous ma tub, Dr. Suess ma tub"

[riggerrob 643]

"in accordance with the manufacturer's instructions." If the manufacturer says that Senior Rigger can assemble a reserve onto risers, then it is legal.
Problems arrise when different FSDOs or DPREs come up with their own, unique interpretations of the FARs.
Mains are not TSO'd, so anyone can assemble a main in the USA.
Rob Warner,
FAA Master Rigger

[polarbear 1]

I believe the FAA has the final say. If they rule that assembling canopies requires a Master rigger, it doesn't matter what the manufacturer's say. Again, this question came up because a DPRE seemed to think the FAA required a Master rigger.
Having said that, I have checked all the owner's manuals I could get my hands on, and they all require just a senior rigger...it seems unlikely that ALL of them would say just a senior rigger, if the FAA required a Master rigger.

[polarbear 1]

I found a question on the FAA written exam that clearly indicates any appropriately rated rigger (back, seat, chest, lap) can assemble canopies...Senior or Master doesn't matter. That makes sense.
Looks like this was a case of a misinformed FAA inspector.