mark

..." .......................................................................... Yes! It is part of the learning process for Senior Riggers to become Master Riggers. Young riggers start by sewing simple patches to the middle of canopy panels. After a few dozen simple sewn patches, then they sew a few patches - including re-sewing seams - under the supervision of a Master Rigger. Eventually, they do complex patches - involving seams, tapes and line attachment points - under the supervision of a Master Rigger. As long as the Master rigger is willing to sign off the repair, it is legal. Eventually, the Senior Rigger tests to become a Master Rigger, but the bottom line is that you have to sew a few hundred patches before you can test for Master Rigger. I'm trying to establish the meaning of "supervise." What is the difference between "supervise" in the context of repairs, and "supervise" in the context of packing? The clause in the regulation uses "supervise" only once. Does the meaning of the word change after a comma? Mark

Had a heart-to-heart with our FSDO guy about that - He was tasked to supervise DZ's and Riggers in the area and the FAA sent him to Idaho and MOntana for a year to rig up there for the smoke jumpers to learn the lingo - my point being that I believe your interpretation is similar to the FAA's... May master riggers supervise repairs made to "live" rigs? Mark

Sport mains are not back type parachutes. The FAA uses the word "type" to mean something different than the casual civilian use synonymous with "kind," "sort," or "style." Only reserve parachutes are typed. No type rating is required to supervise main packing. 65.125(c) exempts riggers from the requirement to have a type rating to pack main parachutes. Mark

That is a perverse reading of 65.125(b)(2) which allows master riggers to supervise packing, maintaining, and altering. To accept that reading, you have to sever the supervision for packing into one class of supervision, and maintaining/altering into another class of supervision. There is nothing in any legislative history, rule-making, or legal action that supports that separation. In fact, there is ample precedent throughout FAA regulations and administrative actions to support the idea that at any repair station there needs to be a person (live, not corporate) who takes responsibility for the work his subordinates perform under his supervision. Those subordinates need not have a rating to work at the repair station. If they did, they wouldn't need supervision, would they? So what would be the point of having supervision as a privilege? I don't understand exactly what the problem is. Is there a safety issue here? Or is there just some sea-lawyering gone overboard? The FAA has some leeway here; there is ambiguity in the regulations. We ought to be helping the FAA interpret that ambiguity broadly to our advantage. Will you be at the PIA meeting in a couple weeks? I asked MEL and got . . . silence. Mark

Thanks! Visit me on Facebook to see more photos. The hardware art is the work of my good friend Merriah Eakins, with a little help from Karl. Mark

Wood or PVC is cheapest, but heavy. Steel pipe is very heavy. Aluminum is lightest. Instead of screwing the clamps directly to the bar, tie them on with a loose lanyard so you can slide them side to side. If you can slide the clamps, your bar can be as short as 6 feet, and you'll still be able to spread the cells of a tandem reserve to full width for inspection one at a time. 10 clamps for 10 line groups, not 9 clamps for 9 cells. I haven't seen any set-up better than my own. For the amount of rigging I do, the extra expense was worth it. YMMV. My bar is a 2" square aluminum tube, 1/8" side wall, with a 3/4" slot milled on the bottom side. I bought the tubing and had the milling done by a local machine shop. Their normal business is working on farm equipment, not airplanes, so I paid farm price, not airplane price. This design allows the clamps to slide freely past the suspension points. Each clamp slide is built up from an eye-bolt, with a 1-1/2" fender washer and 1-1/2" MDS (Nylatron, grey stiffener plastic used in rigs) sandwiched between a couple nylon-insert lock nuts. MDS was originally intended as a friction-reducing bearing surface, not stiffener, and it allows the clamps to slide more easily. To make your inspections easier, put lights on the wall behind the hanger, as well as on the ceiling in front. Mark

I look forward to it. Will you be at the PIA meeting in Lexington next month? Mark

You and I disagree. FAR Part 65 explicitly permits supervision, and in every other aviation context (looking for intent of the regulation here), supervision means, well, supervision of actual work, not just supervision of training. You and I agree that if your seal is on a rig, you are responsible for the all the work ever done on it up to that point. (Yes, senior riggers, you are responsible for any preceding master rigger's work, too.) That responsibility cannot be delegated. Mark

The problem is that we don't have any good non-destructive tests to see if the materials are good enough for continued airworthiness. Certainly after 20 years, rigs made at the same time will have very different histories, so strength and condition tests would have to be done for individual rigs instead of batches. PD does a visual inspection of fabric, lines, and general condition. They check fabric permeability at several places, and do fabric strength pull tests at a few other places. They don't check if there has been any deterioration in the strength of thread, tape, or lines. What would be the equivalent inspection for a harness? A visual inspection may not tell you about deterioration of strength. A pull test to, say, 3000 pounds (a force frequently seen in TSO testing), may be a destructive test. If there is no adequate test, is the best course of action to say that the harness is safe for continued use? One possible solution is to require a test to destruction of some representative components of the system. A para-glider annual inspection sometimes includes deliberately pulling one suspension line to destruction. Lines are relatively cheap; the destroyed line is easily replaced. On an articulated harness, we might pull one of the main lift webs to 3000 pounds and replace it even if it survives. If it survives, that would be an indicator that the rest of the harness was okay too. On an unarticulated harness like Softies, you'd wind up replacing about half the harness. That would be an expensive test, probably not worth it for a 20-year old rig. Mark

The problem with retroactive life limits is that it sets a precedent for Cessna and other aircraft manufacturers. This is something USPA should vigorously oppose. Mark

You just know somebody is going to tell you that removing the Cypres channel is altering the rig's current configuration, and therefore not just a Master Rigger privilege, but one which requires approval from either Sunpath, your FSDO, or both. Why invite responses like that? I'm going to go for "minor repair" -- you are restoring the rig to its original configuration. You probably ought to remove the processor pocket, vinyl control head sleeve, and elastic cutter sleeve while you're at it. Mark

In flat packing, all the cells (except one on the end) are on the "wrong" side of the lines. No greater incidence of friction, burns or tears than in pro-pack. Strong tandem reserves are packed this way. In pro-packing a 9-cell canopy symmetrically, four cells go to each side. So four cells to one side is okay - even though you are pushing center cell fabric in between a whole bunch of lines it will have to extract itself from. If four cells worth of fabric can extract itself from the lines you pushed it through, then four cells to one side is okay for a 7-cell canopy, and for a 5-cell canopy -- and packed that way, those canopies open just as straight as if they were symmetrically packed. Also, there's no greater incidence of friction, burns, or tears. So how about just making sure the stabilizers are flaked to the outside? It turns out, that doesn't matter much either. At the initial stages of inflation (when the canopy is starting to spread but the slider is all the way up), the stabilizers are actually pressurized inward. You do need to make sure there are no lines hitched around the slider stops, but that's about it. Essential steps: _ Lines straight (includes not hitched around slider stops) _ Brakes set _ Slider full size _ Slider against the stops _ Bag locking stows adequate for locking bag until line stretch _ Pilot chute cocked Other steps are for control, or, in some cases, for symmetry (as in reserve packs). Mark

So you are speaking for everyone else??? How did that happen? I know of at least 10 different riggers that you do not speak for... that is just today alone. But....I will give you the data card issue...no pack, no data card entry. So I guess on this point I am speaking for everyone, including you. You are correct, it is not my right but my responsibiity to do it. Semantic nonsense. The old TSO's usually referenced the MIL specs on this. I believe if you will look there you might a few things. I'm not going to do your research for you. You said you believed all manufacturers had standards for damage, wear & tear, an service conditions. You are entitled believe I will find relevent MIL-SPEC references in TSO C-23b, C-23c, or C-23d, or in NAS-804, AS-8015A, or AS-8015B, if only I look hard enough. I won't find any, though, because there aren't any. In any case, MIL-SPECs refer to the standards for goods that will be incorporated into military products. MIL-SPECs have largely been superseded by PIA-SPECs in the parachute industry. None of these specs address the issue of acceptable wear limits for items that are already in service. Those wear limits must be established by the manufacturers. Again speaking for everyone....??? Just speaking for myself and my puppeteers. Explanation accepted. Cheers, Mark

Mark, Sorry, But I just do not get what you are saying. Not complying with a service bulletin is in my world, a defect, therefore I would note that in the log. MEL Well, we're making progress. But you're still wrong. You can write whatever you want on your packing data cards. For the rest of us, FAR 65.131(c) requires "notation of defects found" only when making the entry for a parachute that has been packed. No pack, no entry required by FAR 65.131(c). The data panel on a canopy is not a packing data card. Writing "unairworthy, do not jump" on the data panel is not called for by FAR 65.131(c). It is not packing, it is not a minor repair, it is not a major repair. It may be an alteration, but that's a real stretch, and you'd need FAA or manufacturer approval to make that alteration. It's not your call. And just because you are unable or unwilling to make it airworthy does not give you the right to prevent another rigger or the manufacturer or anyone else the Administrator thinks is competent from doing the work. Further, contrary to what you claim in a previous post, there are very few published damage, wear & tear, or service conditions. For example, the reserve pilot chute is a TSO'd component for TSO C-23c and C-23d. How many holes, how big, how close together are acceptable? How many patches? How much weave separation in the mesh is ok? Finally, the photo of a data panel marked "unairworthy" is not by itself evidence of appropriate action for a rigger to take. There are several reasons why PD might mark the canopy that way. For example, if they wanted to donate a canopy to a rigger school but wanted to ensure it would stay a donation and not be resold, they might mark it "unairworthy." You didn't say the circumstances, and I think we have earned the right to be skeptical. Cheers, Mark

Mark, I consider looking for SB's and AD's part of the inspection. Can you cite the document(s) that provide that info or guidance? From TSO-C23d... TSO-C23d 6/1/94 Page 2 (v) Detailed maintenance instructions, including specific guidance on the limits of wear and damage permissible to webbing material that would warrant replacement. (vi) The quality control inspection and functional test specification to be used to ensure each production article complies with this TSO, as required by part 21, section 21.605(a)(3) and part 21, section 21.143(a)(3). Cheers, MEL Unresponsive. I don't see what looking at SB's and AD's has to do with noting defects found on the data card. I asked you to cite TSO approval documents, you cited the TSO itself. I asked you to say how a manufacturer communicated the limits to riggers in the field. No response. Could you look at my previous post, and respond to it, please? Cheers, Mark

The requirement is to note on the packing data card any defects found during the inspection. For unairworthy parachutes, the rigger options are to make it airworthy, or to refuse to pack it. Defacing parachutes is not a rigger privilege. Please give an example of a specific TSO specification of damage, wear, and service conditions. You should cite the TSO approval documents, not secondary documents like owners manuals. For your example, please explain how the manufacturer has disseminated this information to the field. What is it that "all of the manufacturers do this as far as I know"? Is this a requirement, or not? Cheers, Mark

There are no speed/weight limitations in TSO C23b Standard Category (Vector and Racer, for example. There is no weight limitation in TSO C23b Low Speed Category, and the speed limitation applies to the aircraft, not the freefall speed (Mirage, for example). The 254 pound/150 knot limit is for TSO C23c Category B. For TSO C23d, manufacturers may certify to any weight and speed above a minimum. So it is possible for a C23d Javelin to be rated for a higher weight and speed than a TSO C23d Reflex. When combining a reserve with a harness/container system, maximum allowable weight is the lower of the two weight limits, and maximum allowable speed is the lower of the two maximum speeds. TK -- you are absolutely right. Students should not be test jumpers. Mark

1. MC-4 military rig Rigs: Vector (v382ish) Javelin Infinity Can't find the TSO for Wings, Racer or Icon... Mains: PD Sabre2 260 PD 300 Falcon 300 ZP Manta 320 F111 Manta 290 Man-O-War 320 Rage 230 Icarus 229 PD Navigator 300 Reserves: PD 281 Smart 250 Optimum 253 Falcon 300 Reserves TSO'd for 300 pounds are TSO'd for an exit weight of 300 pounds. If you start at 255 pounds, that leaves 45 pounds for the rig including both canopies, shoes, helmet, altimeter, goggles, jumpsuit, other clothing for non-commandos, plus breakfast and whatever you're drinking to stay hydrated. Mark

The "smaller, thinner pin" is the original pin, one that has been used on parachutes since just about forever. Then, as now, the pin is designed to slide into a hole drilled through the side of a 1x1 (approx) cone used instead of a closing loop. The pin needs to be hard enough not to bend easily, of course, but soft enough that it can be squashed or hammered to flow around and grip the ripcord cable. The Spanish Fly reserve ripcord really was a pull-out pin. It used suspension line instead of steel cable, and a fabric channel instead of a flexible metal housing. IIRC, the ripcord could not be pulled all the way out of the housing, which meant you couldn't lose it (a feature), the handle could entangle with the reserve in case of an unstable deployment (which most folks didn't care about), and you couldn't inspect it for wear (a bug, but one which modern jumpers including me cheerfully accept from UPT these days). Mark

What's old is new again. A Rodriguez rig, the Spanish Fly, had just such a reserve ripcord pin. 30 years ago. Mark

Here's a better method: peel-pull, feel the drop, peel-pull. The biggest drawback to two-hands-per-handle is that it takes a long time to learn the sequence: _ look red _ grab red _ look silver _ pull red _ grab silver _ pull silver Looking here and pulling there is not something that comes naturally -- we would all rather look at the thing we are pulling. Two-hands-per-handle runs counter to our ingrained habits, and under stress we tend to revert to original habits. Under stress, recall of sequence is one of the first thought processes to go. Time spent learning the sequence is time not spent learning pull technique. Left hand assisting the cutaway is not much help if the jumper is trying to shear the velcro apart -- velcro is very strong in shear, and the required left-hand motion is quite weak. A two-hand grip actually makes it harder to peel the velcro. I have personal knowledge of a near-death experience illustrating exactly this problem. Psychologically and physiologically, one-hand-per-handle is the way to go. Mark

The warning label actually says the main canopy must be open 1500 feet above the preset altitude. If you are throwing out your pilot chute 2000 feet above the preset altitude, the main needs to be open within 500 feet. If by "deployed" you meant "open" then you were okay. If you meant "started deploying" then you are a lucky guy. Mark

All the change did was return to the regulation as written before 2001. There was no legal basis for the change made in 2001, so the FAA felt legally obligated to fix it. If you keep asking whether it is legal to replace rubber bands and closing loops, you will get an answer. Consider whether you want an answer, or whether you would like to keep it ambiguous the way it is now. Mark

I hope to get my hands on the newest version this coming week. I do know that there is language that is going to kick it out of Legal for a couple of reasons. One is this new clarification and fix. Cheers, MEL As you know, I wrote most of the PIA's proposed changes to AC 105-2. You know that because I included you in the initial distribution almost a year and a half ago. I invited you then to make contributions to subsequent drafts, and you have had lots of opportunities to comment since, but this is the first time I've heard you suggest there is un-Legal language in our proposal. Discourteous is one word that comes to mind. What specific language do you think is problematic, in the latest or previous revision proposals? Cheers, Mark

Your military static line jumps count towards the numbers you need for licenses, ratings and awards. See http://www.uspa.org/Portals/0/Downloads/Min_BOD_2005_01.pdf, page 27. Mark