mark

It is true that the median test score dropped a lot when questions based on the PRH appeared. However, the vast majority of the problem questions were from TS-100, Standardized Nomenclature for Ram-Air Parachutes." TS-100 was written by Manley Butler, not Sandy Reid, and has been around for 25 years. With respect to the TS-100 questions, the problem was that the questions were not relevant to rigger practice, not that the questions or answers were false or incorrect. You know that no peer review of the PRH would have prevented the FAA from basing questions on TS-100. PRH p7-5, Canopy seam restitching. Machines: 301 straight stitch - light duty 7-11 SPI PRH p7-7, Canopy ripstop tape repair. Machines: 301 straight stitch - medium duty 7-11 SPI (Optional) PRH p7-9, Round and square canopy - basic patch Machines: 301 straight stitch - light duty 7-11 SPI PRH p7-13, Round canopy - panel replacement Machines: 301 straight stitch - light duty 7-11 SPI PRH, p7-15, Square canopy - partial panel replacement Machines: 301 straight stitch - light duty 7-11 SPI PRH, p7-19, Square canopy - rib repair Machines: 301 straight stitch - medium duty 7-11 SPI PRH p7-23, Square canopy - pilot chute attachment repair Machines: 301 straight stitch - medium duty 7-11 SPI PRH 7-35, Square canopy - crossport repair Machines: 301 straight stitch - medium duty 7-11 SPI Mark

Are you referring the questions based on TS-100? Manley Butler wrote that back in the 80's, and most of it is included in Poynter Volume 2. Those problem questions could just have easily referenced the TS-100 directly, or Poynter. It's not the fault of the PRH that the FAA developed trivia questions. What were the specific problem questions caused by incorrect material in the PRH? Mark

I am saying there are no published airworthiness standards for main parachutes. Mark

Umm. Really? I thought your meeting was with AFS-640 and had to do with problems with the written test. Why didn't you invite the folks from AFS-630 who are responsible for the PRH? If you wanted to talk about the PRH, your meeting would have been much more productive that way. The PRH is only of many such handbooks published by the FAA. The FAA tries to update its handbooks every five years, budget permitting. Because the PRH was published in 2005, it is due for revision based on the passage of time. Saying that the FAA is "replacing" the PRH is not saying much at all. Mark

The only place that replacing any suspension line is considered a major repair is in AC 105-2C. The language in the draft AC 105-2D is in line with 40 years of practice following Poynter's Parachute Manual. There are no airworthiness standards for main parachutes. It follows that a main parachute cannot be made unairworthy. There is no such thing as a major repair (as defined above) to a main parachute, and any repairs may be made by a senior rigger. The preamble to the Part 65 revision issued last year does not change that. The regulation does not require the table to be used for anything, just that it be available. No regulations require parachutes of any kind to be packed on a table. ...again not my personal opinion, just fact. I'm not the guy who wrote the book, and I wasn't taught by him. I just run his rigging courses. I would be remiss if I didn't teach senior riggers how to replace lines or do complex patches. And I would be doing them a disservice if I didn't insist they demonstrate the ability to pack the round canopies their certificates will entitle them to pack. Mark

Your test plan is submitted to and approved by an inspector at your local FSDO, whose jurisdiction does not extend beyond the geographical limits of the district, and who may or may not be familiar with the state of the art. It does not represent the position of the FAA as a whole, and other FSDOs may have different standards. Mark

Looks like we're going down that road again anyway. The FAA has never classified relining mains as a major repair, except possibly in AC 105-2C, which is not a regulation and which is open to interpretation. In the most common industry reference, Poynter's Parachute Manual, there are a number of references to line repairs and replacements, and all say a senior rigger certificate is sufficient for line work on a main parachute. That has been the case since the original Parachute Manual was published in 1971. The FAA may have looked at this issue repeatedly, but until they produce something in writing, we can have no confidence in what someone says they purportedly think. Mark

That's debatable. The Minneapolis FSDO and the Scottsdale FSDO both require just one 8610-2. They make sure it's correct, make copies, then sign. Mark

The newest version of the manual on Para-Phernalia's website says 180 days for US. Outside the US, it is whatever your country requires, but not more than 1 year. The same manual establishes a service life of 20 years. Mark

Could you post a copy of his opinion? Mark

Search for TB 252. It's still there. Mark

Here it is. MEL No mention of lines there, either. Mark

What is "The 65.111 Defined"? 14 CFR 65.111 says nothing about installing lines. Mark

Mark, As you know that is still in AFS-100 (Legal) for an interpretation. With that said, it is not definite either way. By the way,when did PIA remove the statement saying it was OK for other riggers to open/close a reserve to change batteries? BS, MEL The common construction is that if something is not forbidden, it is permitted. Until AFS-100 makes a determination, packing a reserve on a rig where some component may need scheduled or unscheduled service before the end of the pack cycle is legal. After all, we can't know at the time of repack whether the system will be airworthy for the next 180 days. It's the owner's responsibility to keep track of that, and bring it back for service as needed. PIA still has that statement on its website. You just have to look for it. Mark

Not exactly. It is legal for a rigger to pack a rig with an AAD that will need service before the end of the pack cycle, just as it is legal for an aircraft mechanic to sign off an annual even though there will be scheduled maintenance due before the next annual. It is not legal to jump with an AAD that requires service. If the required service falls during the repack cycle, the rig is no longer legal to jump until the service is performed or the AAD is removed. Think of it this way: at the time you plan to make your jump, ask yourself . . . reserve inspected and packed within the previous 180 days? . . . AAD meets manufacturer service requirements right now? . . . other parts of the rig also airworthy? The date on the packing data card is not a forecast of serviceability for the next 180 days. It is simply a statement that on that date, the rig was airworthy. It is up to the owner to bring his rig to a rigger whenever it needs scheduled service (like a repack, normal battery change, or AAD replacement), or unscheduled service (like runway rash repair, or battery change because of a low battery indication). Mark

Really? 0.0043 inches is approximately 0.00038 feet (or 0.000000068 miles). The number of significant digits is a measure of accuracy. Using your bizarre definition of significant digits, you are saying if you measure in feet (or miles) instead of inches, you can increase your accuracy. Your calculator can display 8 or 10 or 12 digits, but that doesn't make your calculations any more accurate. This goes to the issue of exit point, winds aloft, and landing area calculations, too. The results of any calculations cannot be more accurate than the starting points of those calculations. Mark

Yeah. I have a question. How do you get accuracy to 5 significant digits when the original number is accurate only to 1? Mark

How much responsibility does the owner have? Mark

I think the intent was to allow a chest reserve to be disassembled from a harness. If you include a continuity check, disconnecting and reconnecting a main parachute is arguably a much more complex operation than simply unsnapping a chest pack. You are correct in pointing out the AS8015A and AS8015B operational requirements for canopy release systems. Mere mention of a component does not mean it has to be produced by a big-M Manufacturer with a TSO production certificate. AS8015A and AS8015B also mention testing with the main compartment full and empty, but no one is suggesting that main parachutes are also subject to TSO. Finally, for years, main canopy manufacturers provided main risers and main deployment bags. For example, before they TSO'd the Swift system, Para-Flight must have had oodles of Cypres-purple ripstop, because that's the color bag they shipped. Mark

The Talon Classic is an accuracy rig, isn't it? Reserve container sized for an adequate landing, main container sized for a huge main? The proportions are quite different for an accuracy rig compared to a FS or freefly rig. If so, and you're getting the harness re-sized because you like the size of the main container, can you get a big enough reserve to fit? Mark

There is no FAR requirement for riggers to put their seal symbols on packing data cards. Mark

A better solution would be for people to stop insisting on a seal to "prove" airworthiness. Regulations require riggers to seal their pack jobs, but there is no requirement for owners to keep the seals on their rigs. Nothing in the regulations says the seal is there to prevent tampering. Further, all the tampering we have seen has occurred with the seal intact. It is the owner's responsibility to safeguard his equipment and make sure it is safe to jump -- the owner is the tamper-prevention device. Mark

OP's client is 240# before gear and will exceed the TSO limits for current manufacture Para-Cushions. Mark

The newer Strong seats are TSO C-23c Cat B (254#, 150kts), so it doesn't help that the C-9 is rated for more. Mark