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Petition for Exemption

Submitted by:

__________________________________________

Allen Silver

Primary Point of Contact for Petitioners: Parachute Industry Association, United States Parachute Association, Experimental Aircraft Association, International Aerobatic Club, International Council of Airshows, Soaring Society of America, United States Forest Service, & United States Department of the Interior

Petition for Exemption

Table of Contents

Petitioners........................................................................................... 1

Sections of 14 CFR for Which Exemption is Sought.............................. 1

Extent of Relief Sought and Reason for Seeking Relief........................ 2

Public Interest..................................................................................... 2

Maintaining an Equivalent or Greater Level of Safety.......................... 2

Summary............................................................................................. 4

Use and Monitoring of the Exemption................................................. 5

Appendix A – Petitioner Contact Information...................................... 7

Appendix B – Previous Grant of Exemption....................................... 10

Appendix C – Supporting Information............................................... 13

Appendix D – Text of CFR Sections Referenced................................. 41

1

Petition for Exemption

Petitioners

  • Parachute Industry Association (PIA)
  • United States Parachute Association (USPA)
  • Experimental Aircraft Association (EAA)
  • International Aerobatic Club (IAC)
  • Soaring Society of America (SSA)
  • International Council of Airshows (ICAS)
  • United States Department of Agriculture (U.S. Forestry Service)
  • United States Department of the Interior (Bureau of Land Management)

Petitioners’ primary point of contact:

Parachute Industry Association
ATTN: Allen Silver
3833 West Oakton Street
Skokie, IL 60076
Phone: 510-785-7070(primary) 847-674-9742(alternate)
Fax: 510-785-9213
Email: Silver@pia.com

Detailed contact information for each petitioner is available in Appendix A.

Sections of 14 CFR for Which Exemption is Sought

This is a petition by the Parachute Industry Association, United States Parachute Association, Experimental Aircraft Association, International Aerobatic Club, Soaring Society of America, International Council of Airshows, United States Forestry Service, and Bureau of Land Management (collectively known as “the petitioners”) for all of their members in good standing, and the pilots who fly them in parachute operations. The petitioners request an exemption from the following sections of 14 CFR:

  • 14 CFR 91.307 (a)(1)
  • 14 CFR 91.307(a)(2)(i)
  • 14 CFR 105.43 (a)
  • 14 CFR 105.43 (b)(1)

2

Extent of Relief Sought and Reason for Seeking Relief

The regulations noted above require a 120-day repack cycle for approved parachutes made of synthetic materials (reserve/emergency parachutes) and main parachutes. The petitioners wish to use a 180-day repack cycle.

Early on, when natural fiber materials were being used in the construction of

parachutes, they were vulnerable to mildew and other rotting agents and required inspection and repacking every 60 days. Synthetic parachute material came into use during the 1940s and 1950s and was far more resistant to mildew than its natural predecessors, thus, safely allowing longer intervals between inspections and repacks. In 1978 the FAA granted an exemption to the United States Parachute Association allowing a 120-day repack cycle (see Appendix B – Previous Exemption). Shortly thereafter, the 120-day repack cycle was adopted as the rule for all users of parachutes.

The FAA identified the advancements that were being made in parachute material and realized that the need for shorter repack cycles had become obsolete.
In keeping with this historical trend, parachute materials have undergone even further advances in technology and the repack cycle should be extended accordingly. The parachute industry is presently using advanced materials in the construction of parachute canopies that allow for slower descent rates and smaller pack volumes. These new materials are treated with special coatings to reduce permeability (airflow through the material). These modern parachute materials continue to be resistant to the effects of moisture and mildew.

Public Interest
Combined, the petitioning and supporting organizations are over 620,000 members
strong. Many are directly involved in parachute operations or are required by the FAA to wear parachutes during their flying activities. This exemption is in the best interest of (and will directly benefit) these members.
However, many of the members are not required to wear parachutes when they fly. By extending the repack cycle, this exemption would reduce the cost of ownership of parachutes. This may encourage pilots who are members of the petitioning organizations to begin wearing emergency parachutes as well as provide parachutes for their passengers. This would have the effect of enhancing the safety of general aviation for those pilots and passengers who otherwise might not wear parachutes.

Maintaining an Equivalent or Greater Level of Safety
Manufacturers of parachutes have determined that frequent handling of the material is actually detrimental to the performance of the parachute. Handling the fabric erodes the coatings and increases permeability. This changes the flight characteristics and increases the descent rate of the parachutes. Both of these factors can have an adverse effect on safety for skydivers or pilots should they need to use their parachute in an emergency. Extending the repack cycle to 180 days will reduce the amount of handling on a typical emergency or reserve parachute by 33% (two repacks per year instead of three). Attached to this petition (Appendix C – Supporting Information) are supporting letters
from the following manufacturers and industry professionals attesting to the fact that frequent handling of parachute material adversely affects its permeability:
• Rigging Innovations
Manufacturer and developer of parachute harness/containers
• Australian Parachute Federation
• Free Flight Enterprises, Inc.
Manufacturer of parachute canopies
• Performance Textiles, Inc.
Worldwide supplier of parachute and hot air balloon material
• Silver Parachute Sales & Service
Pilot emergency parachute sales and master rigging services since 1972
• Sun Path Products, Inc.
Parachute harness/container development and manufacturing
• HLC Industries
Producer of parachute material since 1980
• Altico
Master rigger and parachute harness/container designer
• Paratec
Parachute systems developer since 1985
The United States Department of Defense has also implemented repack cycles in
excess of 120 days. Specifically, the U.S. Army Special Operations Task Force, the U.S. Naval Air Warfare Center, and the U.S. Marine Corps utilize 182-day repack cycles. The U.S. Army’s Airborne Operations have been using 365-day repack cycles for over 20 years. The U.S. Air Force Academy has recently implemented a one-year repack cycle. U.S. DOD Contact information is included in Appendix A.

Many foreign countries have been using repack cycles longer than 120 days for many years with no decrease in performance or reliability of approved parachutes (the same equipment used in the United States). The following list was compiled and published in the October 2004 issue of Skydiving Magazine:

Country Repack Interval
• Australia 6 months
• Austria 180 days (longer if manufacturer allows)
• Belgium South 12 months
• Bulgaria 6 months (unless manufacturer recommends different interval)
• Canada 180 days
• Cyprus 6 months
• Denmark 6 months
• Estonia 6 months
• Finland 6 months
• France 12 months
• Germany 12 months
• Hungary 6 months (unless manufacturer recommends different interval)
• India 6 months
• Ireland 180 days
• Kenya 12 months
• Luxembourg 6 months
• Netherlands 6 months
• New Zealand 6 months
• Norway 6 months (considering a change to 12 months)
• Poland 6 months
• Russia 6 months
• Slovakia 6 to 12 months (depending on manufacturer recommendations)
• South Africa 6 months
• United Kingdom 6 months
• Venezuela 6 months (considering a change to 12 months)

It should also be noted that Australia, New Zealand, and the United Kingdom have been using six-month repack cycles for over 10 years.
Also included in Appendix C is information extracted from a 1999 report by the
Parachute Industry Association’s technical committee in regards to a 180-day repack cycle. This report cites tests conducted by the Belgian Army as well as two parachute manufacturers (Precision Aerodynamics and Performance Designs).
New technology has brought about better and safer methods of parachute construction that has made the old requirements for a 120-day repack cycle obsolete and even detrimental to safety. The petitioners sincerely hope the FAA will continue its historical trend of increasing the time between repacks to obtain a level of safety equivalent to or greater than current standards.

Summary
The Parachute Industry Association, United States Parachute Association, Experimental Aircraft Association, International Aerobatic Club, Soaring Society of America, International Council of Airshows, United States Forestry Service, and Bureau of Land Management request an exemption from 14 CFR 91.307 (a)(1), from 14 CFR 91.307(a)(2)(i), and from 14 CFR 105.43 (b)(1) which require a 120-day repack cycle for approved parachutes made of synthetic materials, as well as from 14 CFR 105.43 (a) which requires a 120-day repack cycle on main parachutes. Members in good standing of these organizations, and the pilots who fly them in parachute operations wish to use a 180-day repack cycle.

Excessive handling of modern parachute materials increases the permeability and
adversely affects the flight characteristics and descent rate of approved parachutes. Extending the repack interval, and thereby reducing the amount of handling, will lead to an increase in the safety and performance of approved parachutes. There is overwhelming support by industry professionals and manufacturers for extending the repack cycle to 180 days.

Collectively, there is support from various organizations comprising over 620,000 members and users of parachutes. We feel strongly that the enhanced safety and parachute performance is in the interest of the public good.

Use and Monitoring of the Exemption
Use of this exemption shall be limited to members (either individuals or companies including their staff) in good standing of the organizations listed as petitioners, and the pilots who fly them in parachute operations. As always, the responsibility for compliance with all laws and regulations lies with the user of the parachute (i.e. pilot or parachutist). Parachute riggers shall not be responsible for determining membership status of the aforementioned organizations.

The following procedures are proposed to monitor the results of granting this exemption:
AT EVERY REPACK:
All parachute riggers will be requested to complete the
“180-Day Exemption Rigging Report” whenever an approved parachute is packed. This form will contain the rigger’s name, license number, and symbol, as
well as the date when the parachute was packed, the date of the last repack, and the total number of days between repacks. A sample form is shown at right.
The rigger shall indicate on the form whether any noticeable deterioration of the parachute has occurred since the last repack. If the rigger did not perform the last repack, then the box labeled “unknown” should be checked. If the rigger indicates that deterioration has occurred, then the rigger shall describe the nature of the deterioration and whether or not it is related to the interval between repacks.

Examples:
1. A rigger notices a tear on the container of a parachute that was obviously caused by snagging on a rough edge in the aircraft. This tear was NOT present at the last repack. The rigger would check the “yes” box (because deterioration has occurred since the last repack), but then explain that the tear was caused by a rough edge and is unrelated to the interval between repacks.
2. A rigger notices a scuffed area on the container that WAS present at the last repack.
The rigger would check the box labeled “no” since no further deterioration has
occurred since the last repack.
3. A rigger notices UV damage on the container of the parachute, but the rigger does not know if this was present at the last repack because a different rigger packed the parachute the last time. The rigger would then check the box labeled “unknown.”
4. A rigger notices deteriorated rubber bands on a parachute that has not been packed for three years in a humid environment. The rigger would check the “yes” box and explain that the deteriorated rubber bands are related to the three-year interval between repacks and the environmental conditions.

WHEN AN EMERGENCY OR RESERVE PARACHUTE IS DEPLOYED:
Riggers are requested to complete the 180-Day Exemption Rigging Report form with the following information: date of deployment, date of last repack, and total days packed before deployment. A brief description of the deployment will be included and shall describe whether the deployment was successful and any additional factors that may have contributed to the outcome. For instance, if a deployment was unsuccessful, it should be noted whether low altitude, excessive speed, or other factors played a part in the outcome. This will help determine whether the time between repacks was a factor in the success of the deployment.

THIS RIGGING REPORT IS INTENDED ONLY AS A MEANS OF GATHERING DATA
FOR STATISTICAL PURPOSES AND IS NOT INTENDED TO REPLACE THE
EXISTING PROCEDURES FOR INVESTIGATION OF INCIDENTS AND ACCIDENTS.
The rigging report form will be available online and electronically submitted to the Parachute Industry Association’s Technical Committee. The information contained in these forms will be compiled and made available to the FAA in an annual report (or upon request) in order to monitor the effect (if any) of the exemption, and to gather data for later rule making purposes.

Appendix A – Contact Information
Primary point of contact regarding this exemption
Parachute Industry Association (PIA)
Point of Contact: Parachute Industry Association
ATTN: Allen Silver
3833 West Oakton Street
Skokie, IL 60076
Phone: 510-785-7070(primary) 847-674-9742(alternate)
Fax: 510-785-9213
Email: Silver@pia.com
United States Parachute Association (USPA)
Point of Contact: Edward Scott – Director of Government Relations
United States Parachute Association
1440 Duke St.
Alexandria, VA 22314
Phone: 703-836-3495
Fax: 703-836-2843
Email: govrelations@uspa.org

Experimental Aircraft Association (EAA)
Point of Contact: Earl Lawrence – V.P. Industry and Regulatory Affairs
EAA Aviation Center
P.O. Box 3086
Oshkosh, WI 54903-3086
Phone: 920-426-4800
Fax: 920-426-6560
Email: elawrence@eaa.org
International Aerobatic Club (IAC)
Point of Contact: Lisa K. Popp

International Aerobatic Club
P.O. Box 3086
Oshkosh, WI 54903-3086
Phone: 920-426-4800
Fax: 920-426-6560
Email: iac@eaa.org

Soaring Society of America (SSA)
Point of Contact: C. Dennis Wright – Executive Director
The Soaring Society of America
P.O. Box 2100
Hobbs, NM 88241-2100
Phone: 505-392-1177
Fax: 505-392-8154
Email: cdw@ssa.org

International Council of Airshows (ICAS)
Point of Contact: John Cudahy – President
International Council of Airshows
751 Miller Dr. S.E., Suite F-4
Leesburg, VA 20175
Phone: 703-779-8510
Fax: 703-779-8511
Email: cudahy@airshows.org

United States Department of Agriculture (U.S. Forestry Service)
Point of Contact: Pat Wilson – Smokejumper Technical Specialist
U. S. Forestry Service

National Interagency Fire Center
3833 S. Development Ave.
Boise, ID 83705-5354
Phone: 406-329-1015
Email: pwilson01@fs.fed.us

United States Department of the Interior (Bureau of Land Management)
Point of Contact: Jim Olson – Equipment Specialist
Bureau of Land Management

Office of Fire and Aviation
3833 S. Development Ave.
Boise, ID 83705-5354
Phone: 406-329-3904
Email: jimolson@fs.fed.us
United States Army
Point of Contact: CW3 Jimmy Taylor, Active Duty Liaison

TACOM/Integrated Logistic Support Group
US Army Natick
Phone: 508-233-6012

United States Army Special Operations Task Force
Point of Contact: John Hawke
Aerial Delivery RDT&E
Phone: 910-907-1049
Email: hawke@aosa.army.mil

United States Navy
Point of Contact: Lisa Wiitala – Team Leader, Personnel Parachute Program
U.S. Naval Air Warfare Center – Weapons Division, China Lake
Bldg. 2466, Room 1600 W
China Lake, CA 93555-6100
Phone: 760-939-0808
Email: lisa.wiitala@navy.mil

United States Marine Corps
Point of Contact: SSGT Steve Pope
MARCORSYSCOM Raids & Recon
Bldg 3240, Range Rd.
Quantico, VA 22134
703-784-9758
popesb@mcsc.usmc.mil

United States Airforce Academy
Point of Contact: Marty Jones

United States Airforce Academy
98 FTS/9201 Talon Dr.
USAF Academy, CO 80840
Phone: 719-333-3671
Email: marty.jones@usafa.af.mil

Appendix B – Previous Grant of Exemption

Appendix C – Supporting Information
This section contains letters from the following organizations expressing their support of
this petition for exemption:
Manufacturers & Industry Professionals in Support of a 180-Day Repack Cycle
• Rigging Innovations
• Australian Parachute Federation
• Free Flight Enterprises, Inc.
• Performance Textiles, Inc.
• Silver Parachute Sales & Service
• Sun Path Products, Inc.
• HLC Industries
• Altico
• Paratec
Supporting Organizations
• Parachute Industry Association
• United States Parachute Association
• Experimental Aircraft Association
• International Aerobatic Club
• Soaring Society of America
• International Council of Airshows
• United States Department of Agriculture (U.S. Forestry Service)
• United States Department of the Interior (Bureau of Land Management)
• Aircraft Owners and Pilots Association

The following information was extracted from a May 1999 report
by the Parachute Industry Association’s Technical Committee
regarding the 180-day repack cycle.
This document was the result of more than 50% voter response
and a greater than 3 to 1 margin for its passage.
Source: Parachute Industry Association website, www.pia.com
6/19/99 PIA180_2

Comments on the 120 Day vs. 180 Day Repack from the PIA Technical Committee:
What is a rigger certifying when he signs the data card?
Does the need for regular maintenance justify the 120-day cycle, or even a shorter cycle?

The technical committee believes that the inspections and the maintenance are two different things. The best way to approach this issue is to draw a parallel to aircraft inspection and operation: An aircraft may not be flown in the US unless an appropriately certified individual has inspected the
aircraft within the past year. However, the fact that the inspection has been signed off does not mean that the aircraft is airworthy or will continue to be airworthy. The regulations state that it is the aircraft operator’s sole responsibility to determine that the aircraft is airworthy, and he must do so before each and every flight. The date of the last annual inspection is only one of the items that must be checked. If the operator’s preflight inspection indicates something is not airworthy, he must correct the problem if the
regulations permit him to do so, or find a properly certified individual to correct the problem before he flies the aircraft.

We interpret the current parachute regulations in the same way. When a rigger has signed off a pack job, he is signing off that he did the inspection and pack job correctly and has completed any maintenance necessary at that time. He is not certifying that the user will not damage or destroy the parachute before the next repack is due. The sole responsibility for determining the airworthiness of the parachute system lies with the operator of that system, and a current repack sign off is only one of the items that needs to be
checked.

In both the aircraft and parachute arenas, the time based inspections are a convenient time to do any maintenance, but those inspections are not the only time maintenance is appropriate. The actual need for maintenance is determined by the extent of use in between these inspections. Some parachute systems may
need maintenance weekly if subjected to a high level of use or abuse, but that is separate from the need for repacking of the parachute purely based on elapsed time. Do some parachutes require more frequent inspections than 180 days, due to the nature of materials used in manufacture? Yes, parachutes made with natural fibers. These materials, such as silk or cotton, are subject to mold, mildew, and rot. Proper storage of such parachute systems is critical to proper functioning. There are probably very few of these systems in use. The FAA originally created a repack cycle of 60 days due to the limitations of these materials. In the 1940s, parachutes made with man made fibers came into use, and with newer systems, mildew, mold, and rot are no longer a big problem if a parachute is kept reasonably clean and dry. The FAA, not willing to totally forgo the time based inspection system, eventually changed the repack cycle to 90 days for parachutes made with no natural fibers, then later to 120 days. PIA is an international organization, and several of our members come from countries where the cycle is 180 days.

In all the governing organizations polled by the technical committee in countries that have changed to a 180 day cycle or longer, there were no reports of any increase in system problems due to the length of time
a system had been packed. For example, Great Britain requires a report of every malfunction or deployment problem and receives approximately 300 per year. During the time they have had a six-month cycle, “none of the reports have suggested that any of the malfunctions or deployment problems were
caused or influenced by extending the cycle.” Also they reported that there was, “ … no mention of any deterioration in any of the components, including rubber bands…in systems opened for repack, sometimes for a year or more.” All the other countries reported similar results.

Should parachute manufacturers stipulate their own inspection cycles as do the aircraft manufacturers? The case could be argued, and there are some people on the committee who feel that they, as manufacturers, know their system better than anyone, and certainly well enough to stipulate a longer inspection cycle than 180 days. However, the committee is not currently proposing this.
6/19/99 PIA180_2

In some military organizations, the cycle ranges from 180 days to six years, depending on the type of system, and the environment in which it is stored and used. Currently, there is no vehicle to allow this in the US civilian parachuting arena.

There is no question, however, that if a material used in future designs has environmental limitations that require more frequent repacks, they have the responsibility and the obligation to stipulate more frequent inspections in this case, and the FAA should allow this. The TSO tests include harsh environmental tests that should uncover this situation, and any reputable manufacturer would certainly do a thorough job in researching any unproven materials used in new parachute systems. Might frequent repacking adversely effect the airworthiness or performance of some parachutes systems? In some cases, definitely yes. Parachutes made with very low porosity fabrics, (0-3 cfm permeability) do experience some degradation in performance due to an increase in porosity caused by handling the fabric during packing. In particular, for ram air parachutes, the change is quite noticeable, and can lead to the parachute eventually failing to meet TSO standards. For this reason, the Technical Committee is recommending that the repack cycle be extended to at least 180 days on ram air parachutes. Since the performance degradation is less severe on round canopies, the technical committee has not formed an opinion on extending the cycle for round canopies.

With few exceptions ram air reserves are made with a very low porosity fabric, for greater resistance to high speed tearing as well as great environmental stability. There is also a great deal of good experience with this type of fabric. Unfortunately, the trade off is an increase in porosity due to handling. By minimizing the frequency of repacking, the canopy’s porosity is maintained proportionally longer, resulting in greater safety for the user. A summary of the evidence for this follows:
The Belgian Army Para School Testing: The Belgian Army has conducted an extensive long-term study of parachute wear on systems used by the school. They were very interested in the effect of high altitude deployments possibly accelerating the performance degradation they were experiencing on their main canopies. From the first part of their study, they concluded that there was no direct relationship between the exact number and type of jumps and the degree of increase in porosity measured, though the porosity increase was great enough to effect performance. They also concluded that the handling during packing was much more detrimental to the parachute than the actual deployment and use. This led the Belgian Army to question their beliefs about their reserve parachutes, “which we assume(d) stay brand new forever.” In checking some reserves in their systems, they found porosity readings as high as 18 cfm in some areas of a parachute after only 30 repacks had been performed. A full 32% had porosity readings of more than 9cfm, with all parachutes tested having a porosity of at least 5 cfm in the center cell. The original mil
specification, now a PIA specification, for the fabric used on this particular
fabric requires 0-5 cfm when new. Among their conclusions was their standard practice of reusing a reserve canopy as a main without further checks had to be changed, and, “A reserve doesn’t stay a brand new canopy.” They also concluded that the idea of, “having a check up after (a certain number of)
repacks is not a bad idea.” Note that the emphasis is on the number of repacks, not the period of elapsed time, because it is the handling during the repack that causes the wear.

Study by Precision Aerodynamics Inc. on Parachute handling vs. Porosity:
Precision, like most manufacturers, knows that all Ram Air parachutes built with conventional low porosity fabric are adversely affected by handling of the fabric. A study was recently accomplished where 10 different fabric samples were handled 16 times using methods typical of the packing of a parachute.

Four samples were from a well-known company that no longer manufactures fabric, but is commonly seen in parachutes manufactured several years ago. The samples were in new condition and had minimal handling. The other six samples were representative of more modern 0-3 cfm fabric commonly used at this time. Among Precision’s conclusions were: 6/19/99 PIA180_2

After testing, the fabric had porosity increases ranging from approximately four-fold to slightly over twelve-fold compared to before testing. The fabric of newer design has generally better porosity characteristics, in that the fabric starts at lower porosity before handling, and does not degrade to as high a porosity as the fabric of older design. The porosity increases seen in these tests were representative of porosity increases seen on actual parachutes in service. The porosity increases seen on actual parachutes are due to the handling of the parachutes, mainly during the packing process. Parachutes that undergo such a porosity increase may not pass the TSO tests under which the parachute was originally certified. See attached graph.

Precision Aerodynamics Canopy Fabric Study 5/99
Study by Performance Designs Inc. on actual opening and landing characteristics of reserve parachutes:
Performance Designs conducted a study of porosity of 18 reserve parachutes they manufactured between April 1990 and May of 1998. The parachutes ranged in size from 126 square feet to 218 square feet. After measuring the porosity on all the canopies, the company selected one large and one small parachute that
had the highest porosity. These two parachutes were then packed and deployed from reserve containers after an intentional cutaway in the same manner as is done for TSO testing. The result was a noticeable increase in the time and distance required for both parachutes to open, and a very noticeable increase in the skill required to land the smaller parachute softly. The parachutes had been packed 10 and 14 times respectively, and both had only been deployed once before. While both parachutes performed reasonably well at this stage, considering the amount of handling they have had in that number of repacks, they are still far from the porosity level that they will attain after many more such pack jobs. Like any ram air manufactured using similar fabric, these parachutes may degrade to a condition where they may not pass TSO tests. They will certainly degrade to a point that the landing characteristics will not be acceptable to their owners or to the standards of the manufacturer, even if they do pass the TSO tests for landing performance.

Conclusions:
As shown by the supporting evidence above, it can be seen that there is no valid safety related justification for continuing with a 120-day repack cycle. There is however, a valid safety related reason for a longer repack cycle for ram air reserves. On parachutes made with very low porosity fabrics, most of the wear of the parachute canopy occurs during the packing procedure, rather than in the use (deployment) of the Parachute Handling vs Porosity
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Number of Handlings
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Sample 6
Sample 7
Sample 8
Sample 9
Sample 10
F-111 Brand
ExactaChute tm
Performance Textiles
Near Zero
Porosity
Higher
Porosity
6/19/99 PIA180_2
parachute. This wear can lead to a degradation of the parachute’s performance over series of repack
cycles. In the case of ram air parachutes, this degradation may get to the point that the parachute may no longer be able to pass the original TSO tests used for the original certification. Specifically, the landing performance is compromised, as is the time and distance required to open. As the trend to smaller, more efficient ram air reserve parachutes continues, the ram air designs depend more and more on the improvements in porosity characteristics of the fabric they use. Lengthening the repack cycle will improve safety of ram air reserve parachutes. A corresponding safety related reason for a longer repack cycle on round reserves is that the porosity increase results in an increased rate of descent, however this was not studied extensively by the technical committee.

For these reasons, the technical committee suggests that the voting members of PIA support a change to a 180-day repack cycle.

Appendix D – Text of CFR Sections Referenced
• 14 CFR 91.307 (a)(1)
• 14 CFR 91.307(a)(2)(i)
• 14 CFR 105.43 (a)
• 14 CFR 105.43 (b)(1)
§ 91.307 Parachutes and parachuting.
(a) No pilot of a civil aircraft may allow a parachute that is available for emergency use
to be carried in that aircraft unless it is an approved type and --
(1) If a chair type (canopy in back), it has been packed by a certificated and
appropriately rated parachute rigger within the preceding 120 days; or
(2) If any other type, it has been packed by a certificated and appropriately rated parachute rigger --
(i) Within the preceding 120 days, if its canopy, shrouds, and harness are composed exclusively of nylon, rayon, or other similar synthetic fiber or materials that are substantially resistant to damage from mold, mildew, or other fungi and other rotting agents propagated in a moist environment;
§105.43 Use of single-harness, dual-parachute systems. 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 using a single-harness, dual-parachute system,
unless that system has at least one main parachute, one approved reserve parachute, and one approved single person harness and container that are packed as follows:
(a) The main parachute must have been packed within 120 days before the date of its use by a certificated parachute rigger, the person making the next jump with that parachute, or a non-certificated person under the direct supervision of a certificated parachute rigger.
(b) The reserve parachute must have been packed by a certificated parachute rigger --
(1) Within 120 days before the date of its use, if its canopy, shroud, and harness are composed exclusively of nylon, rayon, or similar synthetic fiber or material that is substantially resistant to damage from mold, mildew, and other fungi, and other rotting agents propagated in a moist environment.
All Information in PDF Form.

Posted: 7/22/2005 By: General News


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