mark

MEL, you don't seem to have read what I wrote. Mark Baur said - I am not sure what he means by that. If he is talking about packing, then he is not answering my question. My question is about 65.111(c)(2). This paragraph is about maintenance and alteration; it is not about packing. I said - So, I am well aware that there are no type ratings on mains. What remains is for Mark Baur to tell us what he meant by the statement that any certificate is an "appropriate certificate" No babies going for baths, so no excuse for me. I was not clear. I'm with MEL on this. If the work on a main is a major repair or alteration, then a master rigger certificate is required. No specific type rating needed. Similarly, if the work on a main is a minor repair, any senior certificate is enough. Again, no specific type rating needed. Sorry for creating more confusion. Mark

Just to be clear, I think you're addressing MEL, not me. Mark

65.125(c) exempts riggers from the need to have a type rating to work on a main parachute, so any certificate is an appropriate certificate. (We should take advantage of this by making all the packers get chest-only senior certificates. That way they would be legal to pack without supervision, but they couldn't get in trouble packing reserves or doing maintenance on back-type rigs.) Interestingly, 65.125(c) also exempts riggers from the need to be current when packing or supervising packing a main parachute, which now conflicts with 65.111(c). Mark

No change to that requirement, which is in Part 105.43 and 105.45. In the past, packers were required to be "directly supervised" by riggers. Now, packers are still required to be "directly supervised" by riggers. "Direct supervision" is defined in 105.3, and requires the supervising rigger to personally observe the process to the extent necessary, and to take responsibility for the pack. Mark

Like this? http://www.chutingstar.com/archives/00000111.html Mark

You were led wrong. I don't know of any cases where the FAA has used its authority to impose civil fines against a non-certificate holder, though. Also, if you cause the pilot to get sanctioned, there will probably be other consequences. Mark

Found snagged on a main canopy shipped from Hollister for inspection. Mark

Any "riggers" from Hollister missing a refrigerator magnet?

Ah! Good one! Thanks! Mark

I agree that jumping at weights above TSO placard limits is dumb. What, though, is the FAR that is violated? Mark

In most cases, senior. But better be a good one. Mark

Well, I guess that makes us even. I wouldn't be your rigger. Mark

Yup. Since 1984 I have packed exactly 2 chest type parachutes for use, and neither one was deployed. If you are a civilian, your best course of action is to add a seat rating to your senior rigger certificate. After you have your seat rating, you can pack without supervision. If a pilot rig does not have space to record the number of packs (the way a PD reserve does), then pack it 5 or 10 times whenever it comes in for repack. Mark

Now, for all practical purposes, we don't log our main parachute packing. So, it would not commonly be possible to "present evidence" of main pack jobs. And also for all practical purposes, when you go to a rigging class, you are likely going to pack and log reserve parachute pack jobs, since that's what they are trying to teach you. But a back pack parachute is a back pack parachute, main or reserve. Just one more bit of silliness in our FARs. This is a common misinterpretation, arising from casual or imprecise language. In normal conversation, we use "type" to mean "kind" or "sort." In that sense, a skydiving main canopy is usually worn on the back, so it is a kind of back parachute; a base canopy is usually worn on the back, so it is a kind of back parachute; and so on. However, for the FAA, "type" has a specific meaning. It is short for "approved type," one manufactured under a type certificate, or under a TSO, or a personnel-carrying military parachute . For the FAA, a main parachute is not "typed.". A main parachute is not a back, seat, or chest "type." 14 CFR 65.125(c) specifically exempts us from having to comply with 65.129(a)(the requirement for a type rating) when we pack, maintain, or alter a main parachute. 65.125(c) allows a certificated rigger, without regard to type rating, to pack a main. A chest-only senior rigger may certainly pack a main canopy for someone else to use. Mark

That is the current interpretation of a very few riggers, including a DPRE or two. It is not the current interpretation of the FAA as a whole, although some FSDOs have been convinced by local riggers to interpret the regulation that way. That view arises from the truly horrible job the FAA did with the language changes of 2001. The regulation as written (and quite sensibly largely ignored by most FSDOs) limits supervision to main pack jobs, which means we cannot supervise reserve pack jobs under any condition. Under such a reading, any "supervision" done after 2001 doesn't count, and under such a reading, rigger tickets depending on pack jobs after that were issued improperly. Ludicrous, but that is the logical result of the tortured reasoning of those few riggers. A better perspective is to consider that a rigger may use any tools he needs or wants for any task he is qualified for, including packing. Sometimes I use a very sophisticated tool. Mark Baur

Jeez. A grad student? Really? At Columbia? Really? Ever do any statistics? Mark

What the video shows is that you should not try to freefly feet-to-earth during reserve deployment. Mark

Did you notice the part of the advisory that said there may be a problem with RSL deployments also? In that case, there is a problem with reserve deployment with the main container empty. So there may be a problem with the main packed, and with it unpacked. Which pretty well covers all the bases. Also, without knowing what other factors may contribute (and the advisory listed a number of possiblities), a successful deployment in the loft is not conclusive. Mark

In some cases, it might improve the speed of freebag lift-off. Oversize reserves get squeezed out of container corners, and may prevent riser covers from seating fully. Mark

We have reports of instances were a reserve pin was pulled at a sufficient altitude, etc., but we do not have a way to verify the reports. Eyewitness testimony is notoriously unreliable. For airplane crashes, for example, there is always an eyewitness who reports an in-flight fire, one who reports and explosion, and one who reports that the "engine sounded funny." A large number of skydivers who have experienced AAD fires report their AADs fired high. Do the AADs really fire high? Is the explanation by the AAD manufacturers correct? Are the jumpers reluctant to admit they went low? Some combination of these? If a jumper disappears behind the trees, plenty of folks will estimate altitude based on the angle to the tree tops, without considering how far away the jumper might be. On a clear day, objects appear to be much closer than they do on a hazy day. What we have are anecdotes, and the plural of anecdotes is not "data." Mark

Is the absence of Racers on the "list" an indication of superior design, or is it a reflection of a smaller proportion of rigs in service? For example, if there is a problem with rig design, it may be just that Racers (or other designs not on the "list") are not being jumped in sufficient numbers for the problem to manifest itself. Similarly, if there is a underlying problem and the problem is with AAD firing algorithms, we would expect there to be more incidents involving Vectors and Javelins simply because there are more Vectors and Javelins being jumped. Speaking of AADs, how do we know the problem (if there is a problem) is with harness/container systems and not with the AADs? Is there corroborating information from other data loggers such as Protracs, Neptunes, etc.? Mark edited: I'm not responding to Wendy; just happened to be there when I clicked to make my post.

It depends. If the rig is used by a US citizen or permanent resident, it must have been packed by an FAA rigger within the previous 180 days. If the rig is US TSO'd (Vector + PD reserve, for example), it must have been packed by an FAA rigger within the previous 180 days. If the rig has either a reserve or harness/container that is not US TSO'd, then it may be jumped by a visitor if it is his own rig and if it is legal to use in his home country and if it is packed according to the rules of his home country. BTW, as a US rigger, I have no idea if any of my pack jobs will be good for 180 days. After I deliver a rig to a customer, it is really up to him or her to determine if the equipment is airworthy or if it needs to be returned for service. Mark

You're right, an AC is an Advisory Circular. On the other hand, an Advisory Circular is intended to give a plain language summary of the FAA's understanding of the published regulations. To the extent it is an accurate summary, best practice would be to treat it as if it were a regulation. Mark

Not necessarily. When the regulations were changed in 2001, mostly to include tandem jumps previously conducted under an exemption, there were a number of unintended changes. For example, before 2001, if you wanted to make an intentional jump, you had to have a main, certified reserve, and certified harness/container. After 2001, if you have a single-harness dual-parachute (skydiving) system, it has to have a main, certified reserved, and certified harness/container -- but the regulation is silent on the requirements if you want to jump a single-harness single-parachute (BASE) system, and therefor allows jumping such a system. That's the literal reading of the regulation, even though the FAA never intended legalizing jumps using BASE equipment. The rewrite allowing the next person to jump the system to alter it is another such change. Before 2001, the next person to jump the equipment was permitted to pack the main, but a rigger was required to pack, maintain, or alter the rest of the parachute system. Because these changes were not contemplated in the original Notice of Proposed Rulemaking (NPRM) and were not addressed in the comments and responses, there can be an administrative correction. Because the administrative correction would be based on the original NPRM, another round of comments and responses is not necessary. Mark

That is great news! There were also some off-the-wall questions about stuff like -- what happens to stall speed when sink rate increases -- what happens to glide ratio when weight increases And some trivia questions about stuff like T-beam construction and load-bearing ribs being sewn onto the top surface and into the bottom surface of span-constructed canopies. Are those gone too? Do you have a list of the questions they've agreed to change or eliminate? Thanks, Mark