Rigging Question

[PhreeZone 20]

I was at a DZ I don't frequent that much today and I happened to mention to a rigging examiner that I was going to replace my lower brake lines as part of my rigger training and his reply was thatonly a master rigger could do that and not a senior rigger, He also mentioned that even adjusting the length of the lines or initally tying toggles onto a rig were master rigger only territory. Is this true that only a master can do this stuff? I was under the impression that a senior could do minor things like this.

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And tomorrow is a mystery

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[sdctlc 0]

I thought that could be done except on a reserve, where a Master Rigger was needed. Because there is no TSO on a Main what would stopp someone from doing this, Manufacturer??? My understanding is that I could go and jump a bedsheet if I desired as long as the Container and Reserve was TSO'ed?? Curious about the answer here.

"He who Hesitates Shall Inherit the Earth!"

[Kris 0]

Check the FAR, a senior rigger can work on the lines.

Kris

Sky, Muff Bro, Rodriguez Bro, and
Bastion of Purity and Innocence!™

[alan 1]

You will find that the FARs, to a great degree, are open to interpretation. Common practice and the FARs are not always one in the same as well. Your best bet is to do some reading in PPM and then discuss it with the DPRE in your area. The FARs stress that all work and maintenance be done IAW the mfgr's instructions. All of the manuals I am familiar with state that you need to be a properly qualified and rated senior rigger to assemble and pack a rig, including attaching the toggles. My opinion is that the DPRE you refer to is over the edge a little, especially with respect to the toggles. Changing an entire line set is usually considered to fall into the major repair, modification description and therefore would require a master rigger. I believe there is even a specific question about this on the senior riggers' written exam. In my experience however, it seems to be a common practice for some senior riggers. Replacing a broken line or frayed lower brake lines would to most people be a minor repair and allowed by a senior rigger.

alan

[alan 1]

Yes, you could jump a bedsheet for a main if you wanted to. But, if you wanted to alter it or make any major modification to it, you would need to be a master rigger. Go figure!

alan

[Hooknswoop 19]

Take a look at AC 105-2c and FAR 65.111. It is in the back of the 2001 SIM's.

AC 105-2c:

8.A.
8.A.4.a
10..
11.F.
12.


FAR 65.111:

65.111c
65.111c (3)

Hook

[PhreeZone 20]

In the words of the DPRE if the failure of the work could result in failure of the parachute then only a master rigger can do the work. I specifically asked about new lines and he said only master rigger can put a new line set on a canopy. Also if a seam needs replaced I understand thats a major repair. I asked about addition of dive loops to risers with none and was told thats altering the design of the risers and requires master rigger too. Was I just not understanding how little a senior rigger could do or was I wrong thinking that a senior rigger had more things they could do then just patches and repacks?

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And tomorrow is a mystery

Parachutemanuals.com

[alan 1]

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In the words of the DPRE if the failure of the work could result in failure of the parachute then only a master rigger can do the work.

Agreed, and the sections posted by Hook will clarify.

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I specifically asked about new lines and he said only master rigger can put a new line set on a canopy.

Agreed, as I mentioned before, that will probably show up on the written exam.

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Also if a seam needs replaced I understand thats a major repair.

Agreed, but what if the stitching is failing on a 6" section of the seam. I think we now get into interpretation.

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I asked about addition of dive loops to risers with none and was told thats altering the design of the risers and requires master rigger too.

Interprtation again. What if the dive loops are offered as an option by the mfgr? We ran into a similar dilemma a year or two ago. Some DPRE was interpreting AC105-2C to mean that installing a CYPRES on a CYPRES ready rig was an alteration. The relevant text is on page 30 of PPM vol II, par. 8. He cited a well known rigger for numerous violations. The rigger appealed and won. It was determined that on a CYPRES ready rig this was an assembly and not an alteration. The word that caused the confusion was stating that he had "installed" the CYPRES rather than "assembled" it. So, if a set of risers can be purchased from the mfgr with dive loops and a senior rigger "assembles" a set that doesn't have them, IAW the mfgr's instructions, is it legal? What about a BOC pouch? Hard cutaway cable housings? I have instructions from two different major gear manufacturers that specifically state that a senior rigger can perform the work. As far as line replacements, PPM vol I, page 27, par 5 specifically states that line replacements are the domain of master riggers. Problem is, does "line" mean the complete set or one, in the context in which it is used? I think it is open to interpretation. Would a failed lower brakeline result in the failure of the parachute? No. It would fly normally and could be landed safely. But, what if it failed during a landing approach? I think the answer would then be yes. At the big PIA meetings they hold workshops on rigging tasks such as line replacement. Do they emphasize that only master riggers can do the work?

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Was I just not understanding how little a senior rigger could do or was I wrong thinking that a senior rigger had more things they could do then just patches and repacks?

I don't know, maybe a little of both.

alan

[polarbear 1]

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What if the dive loops are offered as an option by the mfgr?

I got asked a question like this on my rigger exam. I was asked if you want to install B-12 snaps on the leg straps of a rig (to replace thread-thrus), and you can buy that rig new with B-12's, then is it an alteration? The answer was yes. If you change a piece of equipment from its original configuration, it is an alteration. It doesn't matter if you are changing to a different configuration offered by the manufacturer-you are still altering THAT piece of equipment.

In the end run, it is clear that you must follow manufacturer's instructions. Call them and ask.

As far as replacing lower brake lines (or changing their length) or attaching toggles, that should be a senior rigger job. I think the DPRE in this case is going overboard.

"Holy s*** that was f***in' cold!"

[markbaur 0]

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You could jump a bedsheet for a main if you wanted to. But, if you wanted to alter it or make any major modification to it, you would need to be a master rigger.

The manufacturer (that would be you, if you were the one putting the clotheslines on the bedsheet), can alter or make modifications to the main parachute, without needing a master rigger ticket or TSO.

Mark

[Hooknswoop 19]

I read the FA's this way:

For TSO'd gear (harness/reserve canopy);
Major repair/alteration=Master Rigger
Minor repair=Senior Rigger

Non-TSO'd gear (main canopy, from risers up)=Anyone.

If you need a senior rigger's certificate to make minor repairs to non-TSO'd gear, then you would need a ticket or someone w/ a ticket to replace your rubber bands on your main D-bag for you, or to perform the 30 day 3 ring maintenance, or switch out mains for you, or replace your main PC, or even to replace your main closing loop, etc.

Hook

[polarbear 1]

I suppose you can make that argument. It is clear that you must follow manufacturer's instructions, which (at least the ones I have read) allow a non-rigger to perform the tasks you listed.

I think you have to admit that changing brake line lengths or adding dive loops to a riser is a more difficult task than changing rubber bands on a deployment bag. And what about patching canopies? If a non-rigger can do anything to non-TSO'd gear, then that means they can patch their mains, which the parachute manual explicitly says requires a rigger. Hell, if a non-rigger can do anything, then they can replace entire panels in their mains, which the parachute manual specifies is a master rigger job.

I would again point out that nowhere in the FAR's does it say that the requirements of having a rigger's ticket to perform repairs or alterations applies to TSO-d gear only, and the repair section of the parachute manual requires a rigger to perform repairs on a main. The only thing the FARs say a non-rigger can do to their equipment is pack their own main and perform simple assembly/disassembly procedures (which I think covers 3-rings, rubber bands, and closing loops).

Again, it is clear that you must follow manufacturer's instructions. I'd bet if you called up the container manufacturers and asked them about sewing on dive loops, their first question would be "are you a Master rigger?"

"Holy s*** that was f***in' cold!"

[Hooknswoop 19]

I would agree your opinion has at least as much merit as mine. So I guess someone or USPA should contact the FAA, not a DPRE, and get clarification for the masses.

I also agree that home made dive loops by other than a master rigger (as we recently were recently shown) is not a good idea.

What do ya think?

Hook

[polarbear 1]

Yeah...debating the FARs is an uphill battle . Following manufacturer's instructions is about the only clear route to legality.

It also seems as if the strict interpretation of the FARs isn't enforced until an accident occurs. But, of course, then somebody's dead.

"Holy s*** that was f***in' cold!"

[masterrigger1 2]

In regards to the manufacturer's instructions, they can only go so far as to who can do whateverer.
Far example , the Jump Shack has some instructions that are basically; in my opinion; a violation of the F.A.R.'s. They state that a senipr rigger can modifiy(their words) their freebag assembly.
You have to know the F.A.R.'s, their content, and the local F.S.D.O.'s ruling on certain subject matter before actually doing the work.There have been some definitions redefined in the last two years from the F.A.A., here are some:
*Supervised Packing - The rigger has to be close enough to be able to answer an immediate question - no delay
*Any changes made to a harness container from it's original configuration are considered alterations.This means that a rig that had a ROL on it when it left the factory, can not have a BOC pocket put on it by a senior rigger.Remember "to change" is also the same as "to alter".This same Senior rigger could replace a BOC pocket if it came with one.(go figure!)
*Repairs(patches) on canopies(main or reserve) that encompass a seam are considered master rigger work.
*Line repair in any fashion is considered Master Rigger work. The reasoning is that it could affect "airworthiness".
The bottom line is to get the Master Rating as soon as possible and be done with it.
As far as the F.A.A. is concerned, they seem to view the Senior rigger is a beginner rigger, alot like a Private Pilot rating is a beginning pilot .
Mark

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[alan 1]

Interesting. B-12 snaps are part of the harness which is part of the TSO'd system, main risers aren't. I wonder what the distinction is between assembling dive loops onto risers as per mfgr's instructions and altering the risers is. To me, an alteration is a change outside of an original design configuration. The CYPRES assembly case seems to confirm that, but not clearly, since it only applies to CYPRES ready rigs. If my memory is correct, you have to be a master rigger and AirTec approved to make a rig CYPRES ready. But, doesn't assembling a CYPRES into even a CYPRES ready rig alter it from the original form? One has a component that can cut the reserve loop and one doesn't. Isn't THAT piece of equipment altered?

I have to agree with you. In the end, if the manufacturer says I can do it and I follow the instructions, then I feel OK with it.

alan

[polarbear 1]

In the case of the cypres, manufacturer's instructions allow for placing a cypres in a cypres-ready rig, but installing the pouch and channel requires a master rigger. I would agree that putting a cypres into a ready rig does alter it, but it is a pretty simple operation and the cypres manual offers clear instructions on how to do it.

Sewing dive loops on risers? There are no instructions and things like stitch type, material, dimensions, etc. come in to play, plus you either have to sit down and study a riser that already has dive loops or you have to design your own scheme. It is a much more complicated process. That is why I consider it a Master rigger job.

"Holy s*** that was f***in' cold!"

[alan 1]

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*Any changes made to a harness container from it's original configuration are considered alterations.This means that a rig that had a ROL on it when it left the factory, can not have a BOC pocket put on it by a senior rigger.Remember "to change" is also the same as "to alter".This same Senior rigger could replace a BOC pocket if it came with one.(go figure!)

This seems inconsistent to me on the recent ruling about assembling the CYPRES on a CYPRES ready rig. According to this, if the rig doesn't leave the factory with the CYPRES installed, assembled, or whatever, then it has been changed or altered. So, can a senior rigger assemble a CYPRES into a new rig that is CYPRES ready or not? Too much is left open to interpretation and the interpretations are far too inconsistent. The BOC thing is another good example. The original design configuation gives an option of BOC or ROL. A senior rigger is not changing it, they are assembling it. According to "AC105-2C Par 8. Parachute alterations. Parachute alterations are changes made to the FAA-approved configuration."

If a BOC is an FAA-approved configuation, then assembling it is not a change. The AAD issue, in my opinion is also clearly defined by the last sentence of that pargraph. "......the installation of an AAD on an auxiliary/reserve parachute system in which _the manufacturer "does not authorize such installation."_
I have in my hand a copy of RI's instructions for retrofitting a BOC pouch that authorize a senior rigger to do the work. Maybe we need the FAA to define "original configuration". Does it refer to a particular rig/component and how that particular piece leaves the factory door or does it refer to the FAA-approved configuration? Seems to me that question is answered in AC105-2C, but apparently even that is debateable.

alan

[PhreeZone 20]

Follow up question to stir this up even more... what are the odds and consiquences if the FAA would rule against a senior rigger adding a BOC to an ROL contanier, if thats really master rigger domain in their eyes? Then how about if a senior rigger would do minor line adjustments such as lengthing the brake lines?

The way it sounds there is no way that all the mains in the US have thier keeper knots on the toggles tied by a master rigger, even though that seems to be the only one that is allowed to tie them accourding to some intertation of the FAR's.

Are we talking civil court fees and fines with suspension of the licence/rating or are we talking jail time? Thats one thing I've never looked into in my training so far.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[alan 1]

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Sewing dive loops on risers? There are no instructions

Really? What manufacturers have you asked? I have asked for instructions on assembling a BOC pouch and received them and for retrofitting hard cutaway housings. I agree though, if you don't have the manufacturers instructions, then a senior rigger should stay away from it.........although, as in the CYPRES, it is a really simple operation to copy set. The loop that failed.....careless, shitty work and I would bet that individual would do the same even with instructions available. Hell, in the case of a CYPRES, the instructions allow the owner to assemble it and even change the battery, the rigger is only needed for the repack.

alan

[alan 1]

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what are the odds and consiquences if the FAA would rule against a senior rigger adding a BOC to an ROL contanier, if thats really master rigger domain in their eyes?

Odds? Who knows. Even if they ruled against you, you could appeal and win, just ask J. Micheal.

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Then how about if a senior rigger would do minor line adjustments such as lengthing the brake lines?

What would bring this to the FAA's attention? A lawsuit as a result of a fatality? The lawyers would have a field day with this.

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Are we talking civil court fees and fines with suspension of the licence/rating or are we talking jail time?

Civil court? Hmmmm....FAR's.....F=Federal????? Fines, suspension, jail time? I'm a senior rigger not a lawyer. Read the FAR's, if memory is correct I think I can recall mention of suspension and fines. I'm not sure about jail time, perhaps if the circumstances warranted it. Anyone else?

alan

[PhreeZone 20]

>What would bring this to the FAA's attention?

How about a rigger at another DZ accusing another DZ of improper rigging and forcing an FAA investigation? I have a feeling that something similar to this is brewing in my area. *Stupid DZ politics*

And while as a rigger in training I'd like to do my own maintence, I can't get my times to mesh with a master rigger to supervise me. I'm not about to bust the FAR's so I'll leave the canopy with him, but its a bummer for me not to be able to do this myself under senior rigger supervision.

Yesterday is history
And tomorrow is a mystery

Parachutemanuals.com

[masterrigger1 2]

[This seems inconsistent to me on the recent ruling about assembling the CYPRES on a CYPRES ready rig. According to this, if the rig doesn't leave the factory with the CYPRES installed, assembled, or whatever, then it has been changed or altered. So, can a senior rigger assemble a CYPRES into a new rig that is CYPRES ready or not? Too much is left open to interpretation and the interpretations are far too inconsistent. The BOC thing is another good example. The original design configuation gives an option of BOC or ROL. A senior rigger is not changing it, they are assembling it. According to "AC105-2C Par 8. Parachute alterations. Parachute alterations are changes made to the FAA-approved configuration." ]
The FAA came out with the ruling (after much debate from Cliff Schmucker along with others during the J. Michael thing) that a rig that has the installation kit installed at the factory, can be assembled in the field by a Senior rigger. If the kit had to be installed, it had to bre done by either the manufacturer or a Master Rigger with the proper equipment
BS,
Mark

Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

[alan 1]

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The FAA came out with the ruling (after much debate from Cliff Schmucker along with others during the J. Michael thing) that a rig that has the installation kit installed at the factory, can be assembled in the field by a Senior rigger. If the kit had to be installed, it had to bre done by either the manufacturer or a Master Rigger with the proper equipment

Yes, I am aware of the ruling, I have referred to it several times earlier in this thread. The focus here, and my point, is the inconsistent interpretastions of the FARs. By the FAAs own definition, Parachute alterations are changes made to the _FAA-approved configuration._

alan