riggerpaul

The point is that there's conflicting information everywhere. You seem to know what trumps what, but sometimes you say that the rules trump other docs, and other times you say other docs trump rules. While it is great that you have the direct line from god on this, the rest of us mortals have to read the docs and try to figure it out.

Good or bad, and AC-105 notwithstanding, 65.111 says that a certificate is required to repair or alter a main. I do find it interesting that AC-105 says, "Parachute alterations are changes to the FAA-approved configuration." If a main parachute has no FAA approval, how can it have an FAA-approved configuration? If an alteration is a change to an FAA-approved configuration, and a main has no FAA-approved configuration, this appears to say that alteration of mains is not considered alteration at all. Some of the people posting here are quite clear that we must look to the supporting documentation to understand the intent of the regulations. Looking at some of what is in AC-105 might lead a person to believe that mains are not covered by the requirements to have riggers work on them. If we are to look at the supporting documentation to determine the intent of the regulation, what do we do when the supporting documentation seems to add confusion instead of clarity? A new version of AC-105 is supposedly in the final stages of review before publication. It will be very interesting to see if the new version clarifies or further confuses these issues.

... " Can an owner (non-rigger) do any maintenance? Change out a rubber band? Or a main closing loop? Change risers or canopy(leaving the canopy on the links)? Swap canopies (leaving the canopy on the risers)? This is all basic stuff any jumper should know how to do. Stuff I've seen competent (non-rigger) jumpers do. Or am I going to get rich changing out rubber bands and other simple stuff at $0.50 a pop? Their is really nothing to stop you from doing you own rigging. Nothing will happen unless you die. And then, really, what can they do? What the regulations do is to put me at extreme peril should I do something for which I am not rated.

'we didn't get the wording right...' What you have to understand is that 'we' is Mr. Barnette. No one else outside the FAA had ANY input that I am aware of into the language of this fix. I assume it went through legal and perhaps other review at FAA but not outside, AFAIK. First off, I apologize for my wording that can be misconstrued. The "we" to which I refer meant only the people who reap the benefit of this regulation. I did not mean that we, the jumpers, riggers etc, came up with the poor wording. It might have been better to say that "they" had done it to "us", AGAIN. Getting wording to be unambiguous is not easy. I am the first to applaud your efforts. Despite any differences of opinion we might otherwise have, I hope you know that I am always grateful for your efforts. Here we must address the philosophical question - Is the purpose of government regulation to protect me from myself, or is it to protect me from the actions of someone else? I am sad when people hurt themselves by doing things that they are not qualified to do. But all the regulation in the world will not prevent someone from secretly doing something to their rig that leads to their own death. The best you and I can do, Terry, is to help people understand that in rigging, tiny details can and do spell the difference between survival and death. The best we can do is to make it clear to them that if they don't clearly know what they are doing, they should get help from someone who clearly does. Beyond that, we are powerless. If someone thinks that the presence of the regulations will prevent people from doing things that kill themselves, that someone is just pissing up a rope. The only way to do that would be for all the gear to stay in the rigger's hands, to be distributed before each jump, and to be retrieved at the conclusion of every jump. I am positive that nobody among us wants to go there. And even going there wouldn't completely ensure that people don't still do something dumb with gear that should be able to save them to make it fail. The point of the regulation, as I see it, is actually two-fold. First, it establishes what will be allowed when one person offers services to another. To offer to do work for someone else, I must have the appropriate credential myself, or I must be under the supervision of someone who does. Second, it establishes that the certified person has clear knowledge of what the regulations require, so as to establish the liability for failing to provide the appropriate service that I offer. Part of the certification process includes making me aware that there are restrictions on what I do. Ignorance of this is not allowed to be an excuse. Beyond this, all we have is for each to be responsible for our own actions. Got it! Again, I never intended "we" to mean that "we" had done this to ourselves.

Thanks Mark (MEL). I'm glad you don't think I am just arguing about the intent of the reworded regulation. I am just frustrated that after a 5 year process, we still didn't get the wording the way it really should be. Regarding seeing the word in 65.111(c)(1), the two paragraphs are joined with "or", so you shouldn't have to look at 65.111(c)(1) to understand 65.111(c)(2), unless they tell you two. As I said, it would also have been easy to say that the supervisor must meet 65.111(c)(1). Then all would have been nice and neat. To recap, I agree that the ruling is clear on the intent. I am just sad we didn't get the wording perfect. Thanks for the post. Knowing that I got my point across is important to me. -paul

I agree with the both of you too. I just don't think that the new regulation, as written, and without the ruling to look at with it, says what it really means. 65.111(c)(2) tells us who can supervise a person who does not meet the requirement for 65.111(c)(1). It calls for a "currently certificated parachute rigger". To be clear all on its own (that is, without the need to see the ruling), it should say "appropriately rated currently certificated parachute rigger" As an alternative, it could say that the supervisor must be someone who meets the requirement of 65.111(c)(1). But what it actually says is that a "currently certificated parachute rigger" will do. I am a Senior Parachute Rigger with a current certificate. Without looking at the ruling, I meet the requirement as stated in 65.111(c)(2). All I am saying is that, even after a 5 year process to get the wording right, it still doesn't say what we really want it to say. You need to look at the ruling to get it right.

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". In case it was not clear, my question deals with what the new language in 65.111.c.2 requires of a rigger who is supervising a another rigger who is doing maintenance or alterations. I understand that the text of the ruling deals with my question. And reading the ruling makes it clear that the new wording of 65.111(c)(2) does not clearly represent the intent presented in the ruling. My objection to the newly worded 65.111.c.2 is that, without the ruling in hand, one could conclude that a Senior rigger can supervise another Senior rigger making an alteration or major repair. I wonder about this question because the new wording of 65.111.c.2 does not call for a rigger with an "appropriate certificate" to supervise. It only calls for a rigger with a certificate. To refresh, here is the new text of 65.111(c) - Reading this carefully, it is clear that an appropriate certificate is required if you are doing the work alone. But because of the omission of the word "appropriate" in 65.111(c)(2), one might conclude that you do not need an appropriate certificate to supervise maintenance and alteration, but that any certificate is sufficient. I say again, with the ruling in hand, it is easy to see that this is not the intent. But if you are not looking at the ruling, but only have the new text of the FAR, the intent is not clear. To be quite clear, I do not think that a Senior can supervise another Senior who is doing a major repair or an alteration. My objection to the new wording is that it does not clearly reflect the intent presented in the ruling.

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 Now I am a bit confused between what you and MEL are saying. According to MEL, the "appropriate" means "Master" for major work, and "Senior" for minor work. This is not at all about the Type question. As we have determined in the past, mains don't have "Types", since they are not certified. I was looking at the new wording that might be taken to say that while a rigger needs to be a Master to reline a main, a Senior could do it with a Senior supervising, since the supervising clause (65.111.c.2) only says a certificate, possibly any certificate, is required. MEL referred us to the accompanying explanation where they say that appropriate rating are needed for any work or supervision. My point is that the wording is still confused, unless you have the ruling to go with it.

It is all well and good to say that we won't open the door until we are well above the critical firing altitude. But, in fact, the recent case in the USA involved a door on a C206 opening by accident. Nobody intended that door to open when it did. So I sort of must support JohnRich's statement that we should prefer that Vigils are not so near the door. At least that way we have a chance to trap the pilot chutes before they go out the door. What about Tandem mode AADs, where the critical firing altitude is substantially higher? The recent beautiful graphic with all the AAD numbers on it says the Tandem AADs activate at 1900, 2040, and 2200 feet. Shall we keep the door closed to 3000' when there are tandems on board? How

Did you determine if that was proper seal thread? I have no reserve pilot chute handy, but I believe a reserve pilot chute spring supplies a force sufficient to break the seal thread I use. I just tested a loop of my seal thread with my spring scale. The thread broke at 5 pounds, as best I can read my spring scale. So, what else is going on in this situation?

Yes, with the ruling in hand it is clear what the intention was. Still, the FARs are also intended to stand alone, so that a person can read the regulation and see the intent. Reading the new regulation in the absence of the supporting ruling, one must wonder why they were clear that the certificate must be appropriate in 105.65.111.c.1, but failed to include the identical language in 105.65.111.c.2, which is, after all, the very next paragraph. The language was there to be incorporated. How is it that in a 5 year process, nobody thought to eliminate that opportunity for confusion? To be clear, I do not believe that I have ever asserted that there was an intent to allow non-certified persons to pack and maintain main parachutes, except that packing was allowed if the packer was the next jumper. The 2001 changes were wrong to include language that could be interpreted that way. But, the new supporting document also clearly says that it was possible to interpret the 2001 regulation that way, though it was not the the intent of the 2001 change. I will assert that the new change, while not so egregiously confused as the 2001 change, still leads the reader to incorrect conclusions. As such, I am dissatisfied with the new change.

On the other hand, let us not think that they fixed it all once and for all. From the document you linked, I quote the following§ 65.111 Certificate required. * * * * * (b) No person may pack any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person— * * * * * (c) No person may maintain or alter any main parachute of a dual-parachute system to be used for intentional parachute jumping in connection with civil aircraft of the United States unless that person— (1) Has an appropriate current certificate issued under this subpart; or (2) Is under the supervision of a current certificated parachute rigger;As you say, it is clear from 65.111.c.1 that a rigger himself must be appropriately rated to do the work you mention. But 65.111.c.2 calls only for a current certificate to be supervising, not an appropriate current certificate. So they still have left a mistake in their wording of 65.111.c.2, and we are not completely out of the woods yet.

Rubber bands can hold a bag locked. It just takes the right conditions. Single stowed mini bands with appropriately sized, neat bights is all you need. What do you do to be "ready for a bag lock"? Do you want to do that for all the rest of your jumps? Equip the bag correctly, and close it properly, and you won't need to wonder.

I am not happy that you think that this was "a simple mistake that could have been missed by anyone". Even a quick gear check should reveal this error. ANY gear check I do would have found it. So what you are really saying is that someone who did not take the care to ensure that the rig was assembled correctly, put the rig on and made a jump. That's a formula for disaster, and should not be passed off as lightly as you are. As with so many disasters, a series of errors were made, each building on the one before. Eliminating any one would have broken the chain. but, one way or another, complacency ruled, and the rig got into the air. If the rig has an RSL, and the RSL riser had disconnected during the jump, this could easily have been a fatality to report, involving a main/reserve entanglement. Don't take it lightly.

many thanks for the PDF! Nice document! Maybe you would consider making the length of the downfacing arrows proportional to the speeds. Just to make a good document even better.

I'd prefer not to use the converter. PDF is nearly universally readable.

can you convert to PDF? My old office doesn't handle this document.

Though I understand what the parameters mean, I still don't quite appreciate certain aspects of this split personality. Here's what the CYPRES2 manual says -The Student CYPRES can be recognized by the yellow button with the imprint „Student“ on the control unit. It activates the release unit when it detects a rate of descent higher than 29 mph (13 meters per second). The activation altitude is split. In the case of rate of descent being approx. that of free fall, the opening altitude is at approx. 750 feet (the same as with Expert CYPRES). However, should the rate of descent be lower than that of freefall but still above the limit of 29 mph (e.g. with partially opened canopy, or after a cutaway), then Student CYPRES activates the release unit when the altitude falls below approx. 1000 feet (approx. 300 meters) above ground level. The student will then have more time to prepare for landing. Like the Expert CYPRES, the Student CYPRES ceases operation below approx. 130 feet AGL.If the student should have more time to prepare for landing in the case of a partial canopy or a cutaway, why should he not also need/have the same time to prepare for landing in the case of a freefall activation? What benefit is there to waiting until 750 feet for a freefall activation? Part of me wants to think that this is so the instructors don't get a face full of the student's reserve should they be following him down to the basement. But, shouldn't the instructors be long gone by 1000 anyway?

Now you are being pickier than I am. Do you dispute that most people would not claim to have used the reserve if it was not deployed on the jump? Among the general jumping population, what does it mean when someone says he "used his reserve"? It means he deployed it.

Echoing what Mark said, consider 105.43. That regulation begins No person may conduct a parachute operation using a single-harness, dual-parachute system, and no pilot in command of an aircraft may allow any person to conduct a parachute operation from that aircraft So, while the regulation makes special mention of the pilot in command, it also prohibits any person from things too. As Mark said, maybe the FAA has never exercised this aspect of their power, but that doesn't mean you are not subject to their action should they desire to come after you. So, possible violations for either one or both, right? I've gotten ramp checked before a demo once, but everyone was in compliance with regulations. So, I'm not sure what the consequences would have been, but was always told the pilot would get most (not all) of the heat. And as Mark also said, he's never heard of the FAA using their power against a run-of-the-mill jumper. But that doesn't mean they couldn't if it was important enough to them. But, in terms of bang for the buck, going after someone with an FAA certificate of some sort will be an easier battle, and will result in more people fearing the consequences of violations. Loss or suspension of a certificate is a big deal for pilots, and other pilots will likely take note. If joe jumper got fined for something, the other jumpers would not give it a second thought.

I just checked the big 3 AAD manuals. All recommend turning off student or novice devices if possible if you must descend with the aircraft. Different manufacturers have different amounts of detail in the manuals, but all eventually recommend turning the units off when students are descending with the aircraft.

Echoing what Mark said, consider 105.43. That regulation begins No person may conduct a parachute operation using a single-harness, dual-parachute system, and no pilot in command of an aircraft may allow any person to conduct a parachute operation from that aircraft So, while the regulation makes special mention of the pilot in command, it also prohibits any person from things too. As Mark said, maybe the FAA has never exercised this aspect of their power, but that doesn't mean you are not subject to their action should they desire to come after you.

Okay, I see what you are saying. But, as a common understanding, does one use something if it does not actually accomplish the designed purpose? In this case, I chose to define the purpose of the AAD as cutting the reserve closing loop. It hasn't done that yet, though we assume it was ready to. Looking at another skydiving example, my rig has a reserve. I made a skydive, and landed under my main parachute. Did I use the reserve? I think that most people would say "no", even though by your explanation, it would be just as reasonable to say "yes". Now, maybe you want to make a distinction because of the "turning on" aspect of the AAD, whereas the reserve does not need any particular preparation before each jump. So, did I use the car's airbag if I didn't have an accident? Again, I think the common answer would be "no", even though there were steps taken to ready the device when I turned on the car. (Thanks! This is fun. Really.)

Tough crowd today! I can turn something on and not use it. I turn on my sewing machine. Then the wife calls me away. I turn off the machine and leave. Did I use the sewing machine?

Well he jumped with a camera [a mini-cam you can mount on an RC plane]. It's obviously not the HQ-type camera that videographers use which require head mounts and what not, so probably isn't that difficult to use. Nevertheless it takes some focus away from what he's supposed to be doing. Just the fact that he's jumped with a camera with under 25 jumps is a little scary. When I got licensed, he wanted to jump with me while he was/is still doing his solo jumps. I applaud him for knowing how to have a good time and how to enjoy this sport, but he doesn't fully demonstrate understanding of what risks are also involved. I'd like to hear a bit more about the camera. Where was it? You sort of said it was not mounted anywhere. Was he holding it in his hand? Did someone with authority say this was okay, or did he sort of sneak it onto the jump? If he got someone to approve, there's nothing to be done. If he was sneaky about it, then I think it is more than just "attitude", since he was doing something that he more or less knew he should not be doing. Otherwise why be sneaky? If he did it openly and nobody caught it, I am not sure what to say. Someone should be watching him a bit more closely. As you say, he is still a student, and his actions could easily get his instructors and others who are responsible for him into some trouble if he gets himself hurt. Without making a big production of it, you can still ask the S&TA if he is aware that your friend jumped with a camera. Then leave the rest to the staff. But I do feel that they (the staff) deserve to know if your friend is doing things he shouldn't be doing.