BRS 6 Year Repack Requirement ?

[NC Bill]

As my plane's 6 year anniversary approaches I begin thinking about the repack and logistics.

 

Before I go much further in the process my question - is the repack an FAA requirement or a BRS/FD suggestion?

 

From memory the CIRRUS requirement was a repack and rocket replacement at 10 years.

 

The FAQ on the BRS website (http://brsparachutes.com/faq.aspx) states:

 

Q. What maintenance is required on a BRS system?

A. Three maintenance cycles are important.

• First: the unit must have an annual inspection, just like the rest of the airplane.

• Second: the parachute must be repacked every 10 years. This work must be done by BRS (primarily due to the machine pressure packing of the canopy). The parachute and all lines will be removed and thoroughly inspected.

• Third: every 10 years, the rocket must be replaced at an estimated cost of $1,000

 

There's probably not a bigger fan of the 'chute than I. But I also fear MIF (maintenance induced failures). :unsure: If it ain't broke leave it alone. :mad: My plane is flown weekly, cleaned and visually inspected after flight, and kept in an enclosed locked hangar. Not sure I see why the 'chute is any less likely to work as advertised in year 5 any better than in year 8.

 

I'd begrateful if someone could point me to the written word on where a 6 year repack is required.

 

Thanks in advance.

[N544CT]

To get it top of the list for comment so it doesn't get lost.

[Jim Meade]

The BRS guy told me the 1350 HS chutes we have in the canister are heated for something like 18 hours or so and then cooled. He told me but I don't remember why they heat them.

 

 

 

 

 

[Ed Cesnalis]

 

 

I'd begrateful if someone could point me to the written word on where a 6 year repack is required.

 

Thanks in advance.

 

My chute is sitting on my desk, just below the serial number it is printed "Do not use after 2-12"

 

 

 

 

[NC Bill]

My chute is sitting on my desk, just below the serial number it is printed "Do not use after 2-12"

 

My question is sincere. What requires a repack of the 1350 BRS at 6 years?

 

I was hoping someone at OSH could get an answer from BRS & FD since both have a presence there.

 

And FWIW, I live in NC, where prescription drugs are dispensed with an EXPIRATION date 1 YEAR from the date the prescription is filled. That has nothing to do with the expiration date of the medicine which appears on the bottle from which the pharamist dispenses it. That may be 2 or 3 or more year later. If you ask the pharmacist will include that date on the label too - but only if you ask. Talk about a waste of money! And I'm told anecdotally that the U.S. govt uses some medicines up to 3 years beyond that date!

 

But in any case - if you fall off the desk then better NOT pull the "little red handle"

[chanik]

There is a legal requirement. The FAA only requires that you follow the directions in the Aircraft Operations Manual from FD for an S-LSA which in turn states that you must follow the requirments in the manauls from Rotax for the engine and BRS for the chute, Neuform for the prop, etc. So because BRS does explicitly mandate a 6yr repack in their official manual then there is a direct regulatory requirement per 91.327

 

http://ctflier.com/index.php?/topic/1113-brs-1350hs-manuals/

[NC Bill]

Let's follow that trail.

 

FAR 91.327 (b.1): The aircraft is maintained ... in accordance with the applicable provisions of part 43 of this chapter and maintenance and inspection procedures developed by the aircraft manufacturer or a person acceptable to the FAA;

and (d) Each person operating an aircraft issued a special airworthiness certificate in the light-sport category must operate the aircraft in accordance with the aircraft's operating instructions, including any provisions for necessary operating equipment specified in the aircraft's equipment list.

 

Referring to the FLIGHT DESIGN CTLS "Maintenance and Inspection Procedures Manual" as of 14 Sep 2008 there is only 1 reference made to the BRS system that I can find. That is on Page 1-12: "During all service and repair work beware of activating the Ballistic Parachute System rocket!"

 

The FLIGHT DESIGN "Aircraft Operating Instructions" for the CT dated 29 Apr 2008 refer to "Parachute recovery system maintenance" on Page 8-2: "The parachute recovery system requires no maintenance, except observance of the pack intervals for the the parachute and the exchange intervals for the rocket."

 

Let's go next to the BRS "Owner's Manual and General Installation Guide BRS-6... Rev A" (our model). Only 1 of 3 references to FAA are made in the 96 pages are relevant. On Page 7 it says "In addition, there are FAA certified systems currently installed on every Cirrus...(mentions other specific aircraft but NOT CTs or any LSAs) ... as an aftermarket STC product."

 

Next, there's the ASTM F-2316 "Instructions for Continued Airworthiness: BRS-1350 HS for Flight Design GmbH CTLS" that appears on the FD website. Note the disclaimer in the box on the cover page.

"This document has been produced to meet the requirements

of ASTM F-2316 “Airframe Emergency Parachutes for Light

Sport Aircraft” and has not been submitted for approval to the

Federal Aviation Administration (FAA) or any other

government entity."

 

And last (I promise) there's ASTM F2316 - 08(2010) Standard Specification for Airframe Emergency Parachutes for Light Sport Aircraft.

Paragraph 1.3 "This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory requirements prior to use."

 

That' what I've been able to track down. I do not believe anything above requires the CT owner to repack the BRS 'chute every 6 years. Am I missing something? :unsure: Help appreciated

[chanik]

Funnily, I'm usually on the other side of these arguments since there has to be a clear path from the FARs to external, official documents they point to in order to establish a legal imperative. But that is pretty clearly the case here.

 

The FLIGHT DESIGN "Aircraft Operating Instructions" for the CT dated 29 Apr 2008 refer to "Parachute recovery system maintenance" on Page 8-2: "The parachute recovery system requires no maintenance, except observance of the pack intervals for the the parachute and the exchange intervals for the rocket."

 

clearly aims you at the BRS manual. Page 71 of that manual clearly calls out a mandatory repack at 6 years as also marked on the canister. The ASTMs do not directly establish a legal mandate regardless of their contents. FD needs to worry about complying with ASTMs. If that calls for some new action on the part of owners, then they need to create a Service Directive, but the FAA does not have to approve this (the big difference between SDs and ADs). The FAQ on the BRS site does contradict their manual but it also is not a regulatory document so you would not do well trying to defend a hypothetical FAA enforcement action for failing to do a repack with that as the defense.

[S3flyer]

Not FD, but at least one manufacturer allows the owner to decide whether to repack although there are plenty of strong warnings and recommendations to do so. The crux of one of the SBs states:

CONTINUED AIRWORTHINESS: Airworthiness of the aircraft is not affected by an out of servicecondition or expiration of the GRS system repack/revision date, provided this placard is properlyplaced in the aircraft.

[chanik]

I take it partially back. There is no legal requirement to do a repack on the CTLS, like there is on the CTSW. After a detailed offline discussion, and reading the CTLS docs, it turns out that nothing in the CTLS AOI points you to the BRS website. Section 2 of the CTSW AOI absolutely requires you to defer to the maintenance requirements and manuals on the BRS site. No such verbiage appears in the CTLS manual and no explicit repack schedule is outlined in the FD maintenance manual.

[N89WD]

Oh well, I got mine done. I had an extra 800 bones laying aeound anyway Damn thing is the chute is the same in the SW and the LS.

[chanik]

My bad, but I presumed the CTLS AOI had the same language as the CTSW. I'm fairly certain CT didn't mean for it to be left out. Their understanding of FARs seems about on par with their grasp of EE issues like proper grounding. So for instance, on their site they put important sounding things in documentation titled Airworthiness Documents. Sounds alot like an AD, but legally means nothing. With a Service Bulletin, at least the mechanic is required to read and consider, but not necessarily follow it. These things they don't even have to read.

[johngpilot]

Here is the page that flight design has to help you understand some of the requirements and definitions:

http://flightdesignusa.com/support/safety_directives/

 

the links are not live but here is that data:

 

Please use these links for the official Safety Alerts, Service Bulletins and Notifications for your ASTM certified Flight Design Aircraft

 

There are three types of Safety Directives:

 

Service Notification: For notifications that do not necessarily recommend future action but are primarily for promulgation of continued airworthiness information.

Service Bulletin: For notifications that do not require immediate action but will REQUIRE some future action.

Safety Alert: For notifications that require immediate action.

 

Note: Flight Design does not use notices of corrective action (Safety Directives) to promote or make mandatory non-safety of flight related equipment upgrades or additions.

 

CTLS - The current production FD composite Light Sport Aircraft imported in the USA first introduced in 2008.

 

CTsw - The legacy Flight Design composite Light Sport Aircraft last imported and sold in late 2007-2008

 

CT2K - The original composite aircraft imported in small numbers circa 2004

 

MC - A New metal Light sport Aircraft. Series production started in 2010.

 

Originally, Part 91.327 of the regulations required owners or operators to comply with safety directives, but there was no provision in place for recording and tracking compliance. Be advised that recording of the safety directives was revised and instituted in March 2010. This change now requires the status of all safety directives be recorded and to require aircraft owners or operators to retain a record of the current status of applicable safety directives for special light-sport aircraft.

 

Support email: TopService@FlightDesignUSA.com

[Doug Hereford]

NC Bill,

If chute repack is not mandated by Safety Directive, Airworthiness Directive, or Airworthiness limitation, then legally speaking, it is not required. Same goes for all of the other stuff like TBO's, and mandatory parts replacements.

 

Nothing in 14 CFR part 91.327 requires one to follow every word of the manufacturer's maintenance document, only to use the maintenance and inspection procedures contained within it. This also means that any references to task specific training, or required certification levels as stated throughout the manual, are FD requirements, and not law. These FD requirements may in fact at times be contradictory to the relevent maintenance rules (specifically 14 CFR parts 43 and 65).

 

An interesting side note related to the BRS. I cannot find any reference in the CT AIRCRAFT inspection checklist for inspecting this system. Maybe I just missed it. However, if it is not addressed in the checklist, that is a major problem that FD needs to resolve.

 

Doug Hereford

[chanik]

That's right. They could have put it in the checklist linked to the maintenance manual and that would have made it required. This thing http://flightdesignusa.com/support/safety_directives/ is really out of line, BTW. FD may not redefine terms that the FARs aleady have assigned specific definitions for. In this case they redefine 3 established terms and then declare them to be equivalent to another already defined term. Not only does the FAA not permit such slippery language; they are legally not allowed to accept this even if they wanted to. It amounts to allowing a manufacturer modify the FARs which is expressly forbidden for all code of federal regulations.

[Doug Hereford]

All,

I'm going to get a little off topic again....... When one performs a condition inspection on an SLSA, he/she alone is responsible for that inspection. Not FD, not Rotax, not BRS. This is evident in the required sign off (which is found in the aircraft operating limitations item 15). The aircraft (the entire aircraft) is certified by the inspector (not FD not Rotax, not BRS) to be in a condition for safe operation. This condition inspection on SLSA has to be performed IAW the aircraft manufacturer's inspection procedures, not FAR 43 app. D. In the case of the CT, the BRS is NOT addressed in their inspection procedures. This is illegal, and potentially leaves a mechanic hung out to dry. FD should immediately issue a Saftey Directive with instructions to inspect this system for condition, and if they feel it is necessary to insure safe condition, they should include chute inspection/re-pack, and component replacements as required. Subsequently, their inspection procedure should be ammended in their manual to include the BRS inspection, even if they only refer you to BRS' own ICA document.

 

Since I'm on the subject of condition inspections, I will say again. There is NO difference between a condition inspection performed on an annual requirement of when and one performed on a 100 hr. requirement of when. The CTLS checklist makes distinctions for annual vs. 100 hr. with those little boxes in the inspector's initial column to the right of the inspection item. Boxes are omitted on many of the 100 hr. items. THIS IS WRONG! There is only one condition inspection in the SLSA world. Also on the very far right-hand side of the checklist where it gives "minimum level of certification", Cut that part off and throw it away. It means nothing, and is contrary to part 43 and 65. Pilots are not authorized to perform any portion of a Condition inspection on SLSA, and manufacturer's have no authority to change that.

 

 

Kurt if you are ELSA, your operating limitations may be slightly different, and you probably perform condition inspections IAW FAR 43 app. D. I'm sure you have a limitation that gives the required condition inspection sign off language, prohibits operation of the aircraft for a purpose other than certificated (three passenger ELSA?).

 

Again chute re-pack is not legally required unless Safety Directive Airworthiness Directive or Airworthiness Limitation.

 

I did call FD on the BRS omition from the inspection checklist.

 

Doug Hereford

[chanik]

Yep, as an E-LSA all this stuff is academic to me as I have a rather boiler-plate version of Op-Lims right out of the FARs for experimental aircraft assigned to the plane (this replaces my need to follow the FD AOI). Those Op-Lims require an annual condition inspection by A&P or LSRM or me with training. I have the Rotax maintenance training but I still don't do my own annual. E-LSA still has all of the LSA limitations, weight, 2 people, 120kt, fixed prop etc. IFR is OK now.

[Doug Hereford]

Kurt,

As I have said before, I agree that the Safety Directive system is totally out of whack. I assume that was the link you posted. In FD's defense though, they do seem to be trying to follow the relevant ASTM consensus standard F2295-10. To me the problem lies in the fact that the standard doesn't fit with the relevant regulation FAR 91.327. For instance, the term Safety Directive is not even seen anywhere in the consensus standard. Instead you have those three different types of Docs: alert, bulletin and notification. Those terms of course are not found anywhere in the relevant regulations. The FAA needs to fix this by mandating that all SLSA mfg. issue Safety Directives in a form and manner acceptable to them (FAA). In other words, create a specific FAA form, and guidance to complete and disposition it. It should be mandated that all Safety Directives are submitted to the FAA and placed into a publically available data base for research by owners and maintenance providers. Furthermore Airworthiness Directives and Airworthiness Limitations issued against approved products that are installed on SLSA should have to be transmitted via the Safety Directive system.

 

Or we can all just continue to debate the mis-information about manufacturer's and ASTM's perceived authority.

 

Doug Hereford

[chanik]

I would give more credit to the FAA here and less to FD. 91.327 refers to the need to adhere to Safety Directives. 14 CFR 21.190 makes it clear that:

(5) State that the manufacturer will monitor and correct safety-of-flight issues through the issuance of safety directives and a continued airworthiness system that meets the identified consensus standard;

 

So FD is required to document compliance with the ASTM per the FARs but they are also supposed to understand and comply, of course, with the rest of the FARs. The FAA is loose about how that information is made available and exactly what the SD needs to look like. But it is important to remember the legal-philosphical difference here. Namely that the FAA does not "approve" S-LSAs certifications. It merely "accepts" them. That's whay SDs are not ADs. They are not approved or issued by the FAA. The complication of how/where to learn about ADs corresponding to TSOd equipment in an LSA is one of the awkward problems stemming from this difference of approach. For better or worse, the FAA gives LSA manufacturers lots of leeway. More rope to hang themselves with, sometimes.

[Doug Hereford]

Kurt,

I sort of agree. FAR 21.190 is legally all FD cares about. Nothing in it requires them to understand other aviation regs. in this country. Yes I think they should be very familiar with all relevant SLSA rules, with emphasis on 91.327, and parts, 39 and 43, but they are legally bound to the requirements of 21.190. As you accurately quoted, they must monitor for and correct unsafe conditions using a system that meets the consensus standard. If they stop doing this, then the aircraft that they have produced, and want to produce $$$$$$ no longer meet certification requireements (unairworthy). Yes consensus standards, and SD's are accepted, but FAR sect. 21.190 is not, and FD must ahere to it. It seems to me that they basically are following 21.190 by the SD system IAW F2295-10, but the standard is wrong for the system in this counrty.

 

As for AD's on SLSA, an AD is by regulatory definition, an ammendment to the part 39 rule, issued to correct an "unsafe condition" that exists, or is likely to exist......................... so legally speaking, FD must make themselves aware of these unsafe conditions that exist on their product (thats why I used the GTX -330 as an example) and issue a Safety Directive. Furthermore, because we in the field need FD approval to perform aircraft alterations, if an AD is issued against an SLSA installed, FAA approved product, that requires an alteration of that product (many AD's require some form of alteration to be performed) to correct the unsafe condition, as long as that product is installed on an SLSA, legally speaking, compliance with the AD (alteration) is not possible without FD approval. If FD makes themselves aware of the AD (as they are legally required to do), then issues a Safety Directive (all it has to do is refer right back to the AD) that transmits the AD to the field, this SD would constitue FD approval for the alteration, and they have fulfilled their certification basis legal requirement in part 21.190. The fact that they are not doing this is (I believe) in violation of part 21.190. Again, to their credit, FD is much better than most MFG that I have been associated with.

 

The FAA should be forcing MFG's to do this after fixing the SD system.

 

Doug Hereford

[Tom Baker]

Since I'm on the subject of condition inspections, I will say again. There is NO difference between a condition inspection performed on an annual requirement of when and one performed on a 100 hr. requirement of when. The CTLS checklist makes distinctions for annual vs. 100 hr. with those little boxes in the inspector's initial column to the right of the inspection item. Boxes are omitted on many of the 100 hr. items. THIS IS WRONG! There is only one condition inspection in the SLSA world. Also on the very far right-hand side of the checklist where it gives "minimum level of certification", Cut that part off and throw it away. It means nothing, and is contrary to part 43 and 65. Pilots are not authorized to perform any portion of a Condition inspection on SLSA, and manufacturer's have no authority to change that.

Doug , I discussed this with one of the FD engineers a while back. They are trying to use one manual to cover airplanes that go to different countries. In Germany they are taxed heavily for an annual inspection, and not so much for the 100hr. I told them it didn't suit the system here in the states.

[Roger Lee]

Thanks Tom for highlighting that and bringing it to the forefront.

Most of the LSA Mfg's manuals, maint. checks including Rotax are written for multiple countries and they are usually written in their language and then translated so interpretations and procedures from one country to another may not always line up with another countries regs and policies. I know you want to say; then a manual should be written for every country, but that will never happen. This said even planes Mfg'ed here in the states have poor wording and misunderstood regs from the local Mfg. I'm sure it's all part of the growing pains of the LSA industry and will work its way out over the years. I say years because we are dealing with the federal government. Some things could be changed quicker at times, but part of the process has a citizens watchdog group to help protect us from too much regulation

(I know an oxy moron) and everything has to go through and be approved through them. It's not a lot different than you being in a hurry to get somewhere in your car trying to drive faster, but you have the brakes on.

 

Growing pains, it takes time and your in the middle.

[Doug Hereford]

To all,

 

I understand the nuances of their tech pubs, but it doesn't give them a free pass. They are more than willing to take your money when you buy their product. Welcome to business in the USA. You want to play lumberjack, then carry your end of the log.

 

As for the 100 hr annual condition inspection differences, it is up to the individual inspector to know better, and do a complete inspection regardless of what the manual's checklist indicates. I brought it up because there is a constant stream of mis-information related to 100 hr vs annual condition inspections, and I wanted to reinforce the fact that they are the same inspection with the same sign-off regardless of what the manual may indicate.

 

As for the incomplete checklist (absent inspection for BRS) FD gets no quarter. Fix it immediately! Insert above lumberjack metaphor.

 

Doug Hereford

[chanik]

The AD treatment is a good suggestion. I don't have the ASTM 2295 (costs $) but really my main point WRT FARs is that FD should understand that they need to label mandatory notices SDs in the USofA or they carry no legal weight. It doesn't take them more work to correctly title their notices. Mandatory Official Airworthiness or else we drown a puppy Document is just them not bothering to understand 21.190 Sorry if that makes their documentation harder to harmonize with other countries but the FAA won't care. FD has made compliance more confusing with their 'interpretations' so, while the FAA isn't likely to notice until there is some nasty incident, if ever some crinkly, un-repacked CTLS chute doesn't fully open then the FAA is not going to land on the poor, confused mechanic. They are going to hammer FD.

[Doug Hereford]

I agree Kurt. When the plane maple-leafs into the gound because the chute turned into a streamer, the FAA will probably point the gun at FD. Doesn't really help the victims though, and it is obvious to me that everyone on this forum is very aware of that. I just get frustrated that the people that are paid to be the independant third party (no dog in the fight, FAA) are more clueless about the system than us tax paying schmucks. The FAA policy requires periodic audits of LSA MFG, so important safety issues like the ones we have kicked around here, should be center-stage.

No one will ever get me to buy-off on the "it takes years cuz it's the government" bull Sh!#! Most of SLSA problems stem from special interest politics, and uninformed FAA employees.

 

I've avoided saying this before, but I will say it now. Because we as an industry have accepted these lessor design standards (ASTM consensus standards), we need a solid continued airworthiness system now, more than ever.

 

Doug Hereford