masterrigger1

The preamble of 65.111 vividly states that a certificated approprately rated rigger shall be required for repairs, maintenance, and alterations with regards to main parachutes. That is a FAA airworthiness and safety standard. The 'required" certificated rigger is also bound by airworthiness regulation in Part 65. We can discuss this right after the DPRE seminar. The right people will be there to answer our questions basically on the spot. See ya next week. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

That is your opinion. My test plan was reviewed and approved by no less than two FAA inspectors of which both hold back and chest ratings. One is an active everyday rigger type. Again, an approved plan. I actually talked to three different FAA types yesterday to see if I was in line, all three responded as affirmative. The first year that is was used as basis for the written test, the median test score dropped to some unbelieveable number. In order to pass the the test, we have had to teach our students "wrong" answers for certain questions. ...and still do to some extent. i.e., What is the federal standard for stitches per inch used in canopy repair? old, still standard answer in most federal parachute drawings 7-11. ....new answer 8-12 from PRH So with that said, the more we dug into it the more we found and somehow I got to be the pivot man. The biggest issue of all was the lack of peer review. I and several other riggers responded to the very first request from Sandy to help review it as it progressed. I never heard back from him! In regards to trying to improve it, we had a meeting with AFS-630 which included Terry Urban with exactly that in mind. About two months later I get a call saying that they are going ahead and replace it. I did not start this post. But when Skybitch stated that "it should be on every riggers shelf", I felt compelled to point out that it had some issues. Cheers, MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

The written test had issues because the PRH was used for some of the test questions as their basis. AFS-630 was here BTW. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

So you are saying airworthy only applies to a reserve parachute? What document supports what you contend in black and white? The facilities are required also. I guess that I just need to have them also and pack outdoors on the grass. Also see attached. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I do not see it that way, nor do several other people monitoring the thread. You need to go back and re-read the posts were I said that the PDC was an error on my part. Usually an applicant writes in his logbook the exact information that he would write on the data card. Therefore if AIR is missing there, proper recording is not adhered to. Also if they write I&R when if fact they assembled the parachute, failure is also justified. See attached. Stating that I have violated my duty as a DPRE is very offensive ,unjust, and basically defamation of character as I see it. The test standards provide guidance to actually test in that area BTW. If you have not noticed, everyone has seems to missed the boat with regards to the remarks column. ....even the example in the PRH and it has a FAA stamp on it. To recap, the remarks column is supposed to have defects listed there. Sorry that you see it that way> I have been dealing with issues with this book for three years or better. In case you did not know, Several DPRE's, Master riggers and senior riggers had a meeting here in my shop, with OKC last March regarding the issues with the PRH. I have presented some of them. I do not have enough time to do them all. I think the fact that the FAA is replacing the book says enough. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I think it is defined. Major repairs = masterrigger Minor repairs = senior or master rigger Maybe. But I usually do my homework. In this case I was wrong about the PDC, but right about having to include Air in the logbook. Do we need to do another 7 year tenture like we did with the main canopy issue? MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I put in just enough to show that the Ac was trying to add to the regulations. Legal has it in their hands to see about removing it. It is still in draft status.( not active) MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Scott, I f you look and my very first post I do not understand were you keep coming up with I said something about safety related issues other than the relining of mains by Senior riggers. I simply opened the book once you requested some examples and started in the front. The first example was about the differences in the needed 8610-2s. The PRH states just one and two is required. See below: h. Two originals of FAA Form 8610-2 shall be received from the applicant before testing begins. FAA Form 8610-2 shall be completed in accordance with Appendix 2, Instructions for Completing FAA Form 8610-2, Airman Certificate and/or Rating Application, found in this order. The DPRE or inspector should provide FAA Form 8610-2, and give detailed instructions for completing it correctly. (Inspector or DPRE shall copy appendix 2 of this order to provide to the applicant until FAA Form 8610-2 is revised with written instructions attached.) The applicant shall be advised to read and remove the supplemental information (PRIVACY ACT) attached to FAA Form 8610-2. (See appendix 2, figure 2-1.) NOTE: All signatures shall be original, in dark ink, with the name printed in dark ink or type written below or next to the signature. I think this covers the 8610-2 issue.... The next issue was the PDC example. I stated it was incorrect. I stand by the same statement, but for a different reason. I stated that is was incorrect because the Air was omitted in the remarks column when in fact nothing except defects is supposedly needed there. "Inspect and Repack" are not defects, therefore incorrect as we see it now. The truth is now known that the remarks column is reserved for defects found during the operation of reacking. This proves me wrong about the PDC, but just the PDC. "Defects only" is a question that I am presenting to legal. In other words can we (as we always have done) include what is recorded in the rigger's logbook in the remarks column. At the same time if If AIR was omitted int the PDC , it more than likely is omitted from the rigger's logbook as well, as most riggers transpose exactly what is written in their logbooks to reflect the same work performed. The last part would be not in accordance with the regulations as a rigger has to log all work performed in his or her logbook. ...and airing is a required action. I think the above has been presented as regulation, not personal opinion. It all comes down to three things: 1. All actions performed have to be logged in your logbook. 65.131 (a) 1-6 2. "Air "is spelled out in the regulations as being a required action. 65.129(c) 3. The PDC card just needs defects listed in the remarks column to be legal. It does not require Air inspect , and repack in that column, much less the more incorrect version of I&R written there as shown in the PRH. 65.131 (c) So far everything is covered with documentation as per the CFRs. Dead horse buried here! Next relining main as a senior rigger. 65.125 Certificates: Privileges. top (a) A certificated senior parachute rigger may— (1) Pack or maintain (except for major repair) any type of parachute for which he is rated; and Replacing a suspension line is considered a major repair in AC-105-2C paragraph 12. Major repair is defined as one that improperly done, might appreciably affect weight and balance and/or effect airworthiness. See attached definitions- paragraph O. Also to solidify the requirement that main canopies need an appropriate certificate (appropriate meaning as required for the task) to work on them, see attached Part 65 Interp. The old argument was that mains were not regulated nor controlled. This Preamble in Part 65 Interp removes that old, incorrect theory. I think there is plenty here to dispel my "opinion" as being documented fact. I am done with that also. Dead horse #2 buried here. The next thing was about the required 40 foot table. It is required. 65.127 Facilities and equipment. top No certificated parachute rigger may exercise the privileges of his certificate unless he has at least the following facilities and equipment available to him: (a) A smooth top table at least three feet wide by 40 feet long. The PRH states that can pack elsewhere which is a direct violation of the listed CFR. The statement in the PRH is merely personal opinion and also not constant with the CFR that states the rigger "shall have" not "should have". ...again not my personal opinion, just fact. I think you will find that this is enough evidence to support my claims thus far. I have neither the time or desire to sit here and try to convince everyone what several other riggers have already discovered as multiple errors in the PRH. There is always going to be the nah-sayers and people that will argue because they simply were taught differently, especially ones that were taught by the guys that wrote the book. Hopefully the new one will be more correct! MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I never brought up a safety concern until late in this discussion. If you do not see the evidence, you never will. The whole point to the begining of this thread was that I&R is not a complete required documentation. I have shown in the FARs that airing a parachute is a required action.(black and white) I have also shown that the rigger is required to document all work and services peformed.(black and white) I thought ( with error) that the PDC was to reflect the same information that is required in the rigger's logbook. As in the previous post the PDC is only to reflect defects in the remark column as work performed should have already been correctly recorded in the riggers logbook. (black and white) In other words the PDC does not have to have the info but it has to be logged in the rigger.s logbook. If you feel that the above is personal opinion, I do not know what to say to you. It is spelled out right there in Part 65. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

But it needs to be aired according to the Regulations, It is there in black and white. Move away from the PDC and focus just on the riggers logbook. There all work done must be recorded. I found out today from the FAA that all that needs to be on the PDC is what is listed in 65,131 (C) The reason why is that 65.131 (a)1-6 and (b) has been complied with. (i never looked at it like that) So in other words,on the PDC, if no defects are found, the remarks column is to be left blank, All other entries (work performed) need to be in the riggers logbook, This does require ALL work or required actions performed. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Son, You need to catch up on your reading. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

They are still the FAA. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I guess you could, but they admitted to basically not reviewing it as needed. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Not possibly. It does state in AC-105-2C that a line repair is a major repair. Also in the preamble of the latest correction of 65.111, it states that main canopies also require appropriate certificates to do the work desired. And for the ones that do not know, only master riggers are allowed to do major repairs (or someone under their supervision. You know this and it is also the reason the new purposed AC is worded as it is..... c. Major or Minor Repair Determination. When there is a question about whether a particular repair is major or minor, the manufacturer’s instructions, supplemented by The Parachute Manual and The Parachute Rigger Handbook (see subparagraph 13e), may be used as guides. (1) If the procedure calls for a master rigger, it should be considered a major repair. If the procedure allows for a senior rigger, it should be considered a minor repair. The same kind of repair may be classed as major or minor depending on size or proximity to key structural components. For example, a basic patch may be a minor repair if it is small and away from seams, but may be a major repair if it is large or adjacent to a seam. You say that AC-105-2C is not regulatory, but it sure seems to me you are trying to make the purposed new one regulatory here. That goes both ways.... I have to think there is more in writting on my version than your version, but there I go, thinking again. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Again, I show you airing is required by the regs...period. It is in black and white. You are required to log work done. What part of that do you not get! My test plane is subitted and reviewed by the FAA before use. So they must agree with it. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

The only safety issue that I know of is the old deal about relining mains. ...and no, we are not going down that road again! 1. Relining mains has already been classified as a major repair by the FAA (Again) that requires a master rigger certificate or direct supervision under one. 2. It is absolutely amazing that in the PRH, the applicable repairman for relining squares is either a senior or master rigger. Then for relining a Round main (and it is even more simplistic) it calls for a Master rigger only! Basically if you use this book as a reference for relining a square canopy, and you have a senior rigger's certificate without a master rigger's supervision, you will be in violation of your privileges. This one is hard fast. The FAA has look at it repeatedly. Although they were trying to get this justified (the PRH recommendations on applicable repairmen) by trying to push it through in the new purposed AC-105-2C. The book is riddled with personal opinions if you care to look for them. The end! MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I have pointed out to you in Black and White that all work must be recorded, not just some work. you're right ...enough already. Safety was never brought up by myself in this thread. Just mistakes regarding CFRs and etc. And yes it is a long list. Remember this was supposed to be a reference book. Usually reference books hold hardfast facts pertaining whatever the subject matter may be. Two years ago, after the DPRE Recurrent seminar was held, many DPRE's and riggers complained to the FAA about it's material/contents. So much in fact, that one responsible FAA guy actually left Reno early, IIRC. I do not have the time to sit here and hack away at the PRH again. I have done it once for the FAA, just like a few other riggers and DPREs have. I started in the very front of the book,you guys can carry on if you wish.... MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

We were speaking of records required. There is no verbage that speaks of recording the "parachute system, just "canopy" or "parachute". Let it be known I do think more is better in this case for sure. No one has ever disputed that IIRC! I made a statement that the orignal data card usually has the manufacture name on it. That's going off the deep end.... How is it a record then. Record meaning data specific for that item. It either has to have an identify symbol, mark, or number if this record is not permanently attached to the parachute. c) Each certificated parachute rigger who packs a parachute shall write, on the parachute packing record attached to the parachute, the date and place of the packing and a notation of any defects he finds on inspection. He shall sign that record with his name and the number of his certificate. If you read the sentence through, you will note that the the parachute record is already in existence and you are simply writing the required info onto that record. I could not agree more! Cheers, MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Lou, This discussion has split between the rigger's logbook and the parachute record/data card. First the Rigger's logbook. 1.It is undisputed that the rigger has to log all work performed in his/her logbook. 2.Airing, Inspecting, and pack or repacking are required actions. 3.With that said, would you not agree that it is in black and white that the rigger has to log all three in his/her logbook..along with any other notable work? I do not think that is a personal opinion BTW. Parachute Record/Data Card The question here is do we mirror/transpose what is in the rigger's logbook in the remarks column. Until now I would have( and did) say absolutely! To be honest what I am seeing/hearing from the FAA is no. Right now I am hearing that the remarks column is for defects..."defects only" being the question. But back to the example in the PRH, 1. If you mirror/transpose what is required in the rigger's logbook, that example would be incorrect. 2.If the rigger is supposed to log "defects only" in the Remarks column, both the PRH and myself are incorrect. The second is starting to look like that is what it is. In either case the PRH example is wrong. BS, MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Jerry, I guess I did not spell what I intended to spell out. I meant to say that abbreviations and intitals really need to come from an approved list from FSIMS. See attached example. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

Roger on that! MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

In the Ohio tandem incident, it is unclear who exactly did what and when. The other is somewhat Hush-hush because of the lawsuit. MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

....up to the point that it does not violate the regs. You have to abide by the CFR's, your responsibilites, and privileges as a rigger in order to maintain those privileges. What you stated are Givens. What I am speaking of are direct actions that are required in writing in the CFR's. The things thatt you are bring up are not. First, Industry standards (which in this case is not) are not what you follow as a certificated rigger. You follow the regs...are you are supposed too. Since you brought it up Intitals or abbreviations are not really legal in FAA documents which you can find in FMIS. You supposed to spell out words. The FAA hates blanks and lack of format. If you have the time go through there and study some of the stuff in there. Lastly, as I am completely done with this issue, record keeping is a big time concern with regards to two high profile fatalities. This is one reason that it will not be long for the wait! MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

I am not the only one that thinks this. The FAA also knows this to be true now after so many people pointed out the issues. In this case the same guy that wrote the book just so happens to be also the manufacturer. Again, a manufacturer cannot diminish the "standards" set forth by the FAA. Here again I will point out that airing is still a requirement as per the regulations. I just put in a call for you guys to Washington. Let's see what their answer is. It will be pretty quick I'm sure on this one. I guess I am confused. Is airing a parachute still not a requirement? (Fact based) I guess you only issue you have is whether or not you need to write AIR, INSPECT, REPACK in the remarks column on the data card. I guess which ever you do (all or nothing, either blank or A.I.R.) the example in the book would be still wrong..correct? MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com

So ...you just got your rigging certificate and already you know more than the rest of us right? Tell you what, don't put anything on the data card and see where that will get ya! MEL Skyworks Parachute Service, LLC www.Skyworksparachuteservice.com