180-Day Repack Answers

The new FAA rule implementing 180-day main and reserve repack intervals takes effect December 19, 2008. In consultation with the FAA and the Parachute Industry Association, USPA has developed answers to some obvious questions.

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Q: Is there any change prior to December 19, 2008?
A: No, up until that date, the reserve and main must have been packed within the previous 120 days.

Q: What happens on December 19, 2008?
A: Beginning on that date, you can jump a rig in which the reserve and main have been packed within the previous 180 days.

Q: Even if my reserve pack job had previously expired?
A: Only to a point. Beginning December 19, count back 180 days—if the reserve was packed within those 180 days, it is legal to jump.

Q: What about my AAD?
A: Good question. FARs 105.43 and 105.45 hold the “person” (the skydiver and the tandem instructor) responsible for ensuring that an AAD, if installed, has been “maintained in accordance with manufacturer instructions.” You can only comply with that regulation if you know the maintenance schedule and service requirements of that AAD. Do you know when the battery must be replaced? Do you know when the AAD must be removed for factory service? Do you know when the service life ends? If you don’t, prudence requires you to ask your rigger or the manufacturer before you jump a rig beyond its originally intended 120 days.

Q: What if my AAD requires servicing before the end of the 180 days?
A: Our interpretation of the FARs is that when a manufacturer-recommended AAD maintenance/service interval comes due, even if before its 180 days expires, the rig should not be jumped until that maintenance/service is performed. That’s why it is imperative that future AAD service dates are recorded by the rigger, preferably on the packing data card, and known by the skydiver/rig owner.

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Rig owners with specific questions about their rigs should consult with their riggers and/or the manufacturer of a specific component. Technical or rigger-related questions posed here will be forwarded to PIA or the component manufacturer, if USPA is not able to answer with certainty. PIA has also posted answers to FAQ on their website: http://www.pia.com/piapubs/PIA-180FAQ.pdf.

NTSB Update

As USPA has reported, jump plane maintenance and operations were the subject of a National Transportation Safety Board Special Investigation Report on the Safety of Parachute Jump Operations, and not in a good way. Knowing the FAA has a decision to make about how to respond to the NTSB, USPA met with the FAA and proposed a self-regulatory approach, believing that substantive improvements in jump aircraft maintenance and pilot training can be gained without the need for additional federal regulation. But first, USPA and FAA had to agree that all parachute operations that offer services to the general public and/or to experienced civilian skydivers for compensation are “commercial operators” as defined by the general definitions section of Title 14: Aeronautic and Space, Code of Federal Regulations.

14 CFR 1.1 Commercial Operator means a person who, for compensation or hire, engages in the carriage by aircraft in air commerce of persons or property, other than as an air carrier or foreign air carrier or under the authority of Part 375 of this title. Where it is doubtful that an operation is for “compensation or hire”, the test applied is whether the carriage by air is merely incidental to the person’s other business or is, in itself, a major enterprise for profit.

With that established, current regulatory requirements for aircraft maintenance will be reviewed with drop zone operators and a verifiable program developed by USPA. The program will then be implemented through our Group Member drop zones. Guidance for jump pilot initial training, recurrent training, and regular competency checks will follow similar development and implementation. Information on these programs will be distributed in Parachutist, the USPA website, and by direct e-mail communication with our Group Member drop zones.

The people behind the 180-day repack change

On November 19th, the day the new 180-day repack rule was published in the Federal Register, (making it OFFICIAL!), USPA met with two FAA officials who made it happen. Joining me and Randy Ottinger, USPA’s Director of Government Relations, was Cliff Schmucker, President of the Parachute Industry Association.

PIA President Cliff Schmucker (left) and USPA Executive Director Ed Scott flank FAA Acting Administrator Bobby Sturgell while discussing the new 180-day repack rule. Photo by Randy Ottinger.

First we met with and thanked Kim Barnette, the FAA man who shepherded the regulation. (His work is not yet done; he’s already working on answering the resulting questions.) Then we met with FAA Acting Administrator Bobby Sturgell, and thanked him for signing off on the new rule. (Never receiving confirmation, Sturgell is preparing to exit and make room for an Obama appointee.)

Sturgell took great delight in figuring out that, together, his three guests had logged over 7,600 jumps. We might even be able to get him out to a DZ, once he has more time. Altogether, it was a good day spent at the FAA.

NTSB hearing on parachute jump operations

If you watched the web cast of yesterday’s NTSB public hearing, you probably had thoughts similar to mine as I sat in the audience and listened to the special investigation report on jump plane operations. It was difficult to hear about skydive operators who ignored aircraft maintenance requirements and who hired pilots who took a cavalier approach to their responsibilities. While we also heard that all operators shouldn’t be tarnished with what the NTSB found, there’s no denying the evidence that more can be done to make sure operators understand the regulations and then comply with them.

The good news is that the NTSB recognizes that USPA can play a strong role with the FAA in developing and disseminating the programs and guidelines that the NTSB has recommended. USPA must look at this as an opportunity to step up and offer to develop the NTSB-recommended maintenance awareness, pilot training, and pilot testing programs for the FAA to review and endorse. When we accomplish this, our members and the first-jump public can have greater confidence in the competence and professionalism of all of our operators. We—and they—deserve nothing less.

Be sure to read my Gearing Up commentary in the October issue of Parachutist. Though it went to press last week, I felt the need then to address two pervasive urban myths about jump plane operations. In short, skydivers are passengers and jump flights are commercial operations. That needs to be the starting point for the work that lies ahead.

Read the official USPA News report.