Jumping your gear with an automatic activation device comes with a legal responsibility shared between you, your rigger and your pilot. Unfortunately, sometimes one, the other or all three have insufficient understanding of the regulations—or more importantly—the safety aspect of AAD maintenance.
Admittedly, it’s confusing. As the owner-jumper of a rig, your responsibility is clarified in Federal Aviation Administration Advisory Circular 105-2e (the FAA’s own explanation of its regulations) at paragraph 14.a(4):
“A parachute user must ensure that an AAD is maintained in accordance with the AAD manufacturer’s instructions and service requirements. When a rigger packs a reserve parachute, the rigger is only certifying that it meets all safety requirements on the day it is packed; therefore, riggers should note any maintenance or battery replacement due date(s) on the packing data card so that users are able to determine AAD airworthiness and ensure conformance to the regulations. “
So, the rigger must know or look up the service and update requirements of all AADs before packing a reserve. And while the rigger should write on the data card that an AAD is due for service between repacks, it’s still up to the jumper that any required AAD service is up to date. Fortunately, most users need to know the requirements and service expiration date for only one AAD. Naturally, it behooves operations owning multiple AADs to keep track for their users even though the FAA specifies that “user,” not owner, is responsible.
As just quoted from the AC, the rigger may repack the rig only if the AAD meets the manufacturer’s service requirements. That passage is advisory. The regulations for riggers primarily found in 14 Code of Federal Regulations 65 state at 65.129:
“No certificated parachute rigger may—
(b) Pack a parachute that is not safe for emergency use.”
None of these responsibilities end with the user and the rigger. As we all studied as skydiving students, the FAA places the onus for compliance with the parachuting regulations in 14 CFR 105 on the jumper and the pilot jointly and states in 105.43 (c), “If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.” This FAA passage is a rule, not an advisory. But obviously, it’s impractical for a pilot to know what in the world is going on with all 20 or so AADs in his airplane, so must count on:
- The manifest office to keep track of reserve packing records (data cards)
- The rigger to keep track of AAD maintenance before packing a rig and to advise the owner if service is due before the next repack
- Every user, whether the owner or not, to track this information
- The user not ignoring the required service or replacement schedule of the AAD.
Several riggers have recently reported coming across rigs equipped with automatic activation devices that were jumped with expired batteries and unsupported software, despite the rigs having had multiple inspections and repacks over several years. These reports point to the need for more rigorous attention to the upkeep of AADs on the part of both riggers and gear owners.
One AAD in popular use requires an annual check. The user or rigger can perform the check, but it’s complicated by the need for a barometric device to compare against. If the check isn’t logged, it’s impossible to tell if it’s been completed.
Another manufacturer’s service schedule changes according to the date of manufacture and also may be required or optional (stated by the manufacturer as “strongly recommended”) according to the date of manufacture. Yet another has several recalls and battery requirements that require consulting both the website and the manual. Both these AADs have to go to the manufacturer for both required or optional service and updates.
Whether you are a rigger, an owner or a mere user, staying informed about these requirements and verifying compliance is a serious responsibility that ensures equipment meets all safety standards and that the parachute that gets packed is indeed “safe for emergency use.” To protect our pilots, ourselves, other jumpers (think premature openings) and the skydiving operation, both riggers and owners need to consult the user manual and manufacturer website for AAD service and expiration requirements.
Kevin Gibson | D-6943 and FAA Master Rigger and Designated Parachute Rigger Examiner
Rahlmo’s Rigging at Skydive Orange in Virginia