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BRS 6 Year Repack Requirement ?


NC Bill

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Despite my objections to FD and BRS, I shelled out the $846 and $55.34 for frt. & ins. to get my chute done.

Once again I found something that I had been missing on previous inspections.IMHO this all tied into the rush to produce A/C back in 2006.

Once the zip ties were cut to be able to remove the harness from the D-link and when I fliped over the D-link, I noticed that while the D-link nut looked tight and could not be turned by hand, it was cutting into the harness. The fabric covering was like a cookie cutter had cut into it. Luck ! the Kevlar beneath was not damaged. BRS informed me that this would be OK since in our application we do not have exposure to UV or water on the Kevlar.

Ummm! Enclosed in cannister, which is enclosed in A/C, which is in heated Hgr. Makes one wonder why Cirrus has more time. Could it equate to $$ spent on purchase ???

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Hi Bob,

 

I talked to BRS. They said the chute and mount in our plane was designed for the CT and fairly new for BRS. They in fact, according to them recommended the 6 year re-pack because it was a new system. They believe 6 years is a good spot for most on the market. Don't ask me about the Cirrus time because I don't have any facts about that system.

The outside cover to the Kevlar bridle doesn't affect it's strength and is only a protective shield. I have seen some of the firewall installs from other places come in here with the bridle and shield pinched.

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I talked to BRS. They said the chute and mount in our plane was designed for the CT and fairly new for BRS. They in fact, according to them recommended the 6 year re-pack because it was a new system. They believe 6 years is a good spot for most on the market. Don't ask me about the Cirrus time because I don't have any facts about that system.

 

I just spoke with CIRRUS Tech Supp. CIRRUS was the first certified aircraft to be equipped with their BRS model - the CIRRUS AIRCRAFT PARACHUTE SYSTEM. From the time that model was first developed (1999) it has always required a simultaneous 10 year repack & rocket replacement. So I'm still not sure why our "new system" requires a 6 year repack and the CIRRUS system when "new" required it at 10 years? Back then a BRS on an airplane really was NEW ;)

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While you are all chewing on the subject of BRS let me open up another can of worms... In the CTLS AOI, page 1.7 section 1.8 "Minimum Equipment" notice the BRS is NOT LISTED. Note in 1.9 "Recommended Equipment" it does list the BRS. Couldn't one therefore make 2 assumptions: 1.) BRS is not required and 2.) If you are sending off for a re-pack you can still fly your plane without a BRS since its "Recommended" but NOT "required"?

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Hi Adam,

 

You aircraft was certified airworthy with it originally so it needs to stay in. IFFFF you could get an LOA from FD it could be removed.

Yes you can fly temporarily without it. The safety side would far out weight weight consideration and liability concerns. FD has an LOA just for flight while the chute is out for re-pack. You need to mark the handle in op and re-calculate the W&B. That BRS system in your plane is worth about $8K so you might as well feel good about it being there. :)

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If his plane had no chute when it came into the states and got its airworthy cert. no chute would have been fine. Since it came with the cute and it was given its airworthy cert with the chute in place as its original equipment then he would need an LOA to remove it from FD. Before chutes were standard equipment and came in all CT's they would be optional when you ordered your plane. Then it got its airworthy cert without it.

The other item that plays into account is it on your original W&B sheet when it received its airworthy cert.

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I don't think you got the point Roger. Each manufacturer in Standard and Special Light Sport includes a list of required equipment for airworthiness. If something is on the plane but not required, it is just that - not required for flight. Like the sun visors that are standard equipment, but not required. Of course, if an item is removed or added that makes a significant change in W&B that must be changed too.

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The Mfg can list both optional and standard equipment, but once it came here with it installed in an SLSA and the US issued an airworthy cert on it it stays in the plane unless you get an LOA to remove it. An ELSA can do whatever they want.

 

Let's say the chute in the book was listed as optional, but a particular plane was shipped with it installed and was included on the W&B and then the US issued that particular plane its airworthy cert. Then the chute is part of that plane until you get permission to remove it regardless of what the the operators book says as far as optional.

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Hi Doug,

 

I would have to say no if they originally came with them because you would need an LOA to put them in. I sent an LOA in for my visor's. I made them and people here purchased them .

Over the years people have added new ones and taken the old ones out without LOA's.

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So...every manufacturer has a minimum equipment list. The FAA requires it. Under it you can remove a gauge, mark it inop and still fly if it is not on the minimum equipment list. We all learned this in flight school.

 

Are you sure about this?

 

You may be right, but I don't recall one for any plane I've owned, including my Cirrus and Sky Arrow.

 

There is required equipment for different operations listed in the "Limitations" section of the POH, but that's different from a formal "Minimum Equipment List".

 

Here's a link to a discussion on them: http://www.nbaa.org/ops/maint/inoperative-equipment/minimum-equipment-list.php

 

In short, an operator may utilize one, but it's not required under Part 91 for a manufacturer. I also don't think it's commonplace.

 

But I may be wrong. Is a CT delivered with an actual "Minimum Equipment List"?

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Serious mistakes.

 

Since we have been doing BRS re-packs this year I have found 4 bad pull cable installs at the rocket firing pin point. Here is a picture of what should be done and what it should look like. I have found 1 that the cable was on the back side of the firing pin not connected. I just found one that had the cable hooked over the outside of the cable screw and then crushed as the screw was tightened.

This is an easy quick inspection. Pop off the plastic outer cover. Look inside with a flashlight. The looped end of the cable should go up inside the firing pin and then the screw threads in and through the looped end.

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I can't imagine a worse chain of events than... I'm in a position to need the chute... I pull the handle... And nothing happens because of a faulty cable install by some housewife in the Ukraine who had a bad day... Images of Porky Pig come to mind saying "yabea yabea, thats all folks". Definately worth a quick look next time at the hangar!

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Attached here are the 2 documents (one for CTSW, one for CTLS) that make it "law" for the 6 year repack... See item 2 on page 4 of 10. Flight Design and BRS mandate a 6 year repack and 12 year rocket replacement.

 

They would be law if they were issued as service directives by flight design. As they stand, they are outside the document chain specified in 14cfr 91.327 and 21.190 so they are not. Minimum Equipment Lists are governed by 14cfr 91.213

http://www.nbaa.org/ops/maint/inoperative-equipment/operations-without-minimum-equipment-list.php

and barring an MEL (the CTSW doesn't have one, the CTLS does and the BRS isn't on it) you go by the regular equipment list which must be in the AOI is supposed to be as equipped when issued the airworthiness cert. That is also very poorly done as it lists such things as 3 tone paint scheme and rotax warrantee. So in theory I couldn't fly with two tone and I need to add RW to my ARROW list.

 

Bertorelli has a funny line I totally concur with about LSA AOIs in his latest article http://www.avweb.com/blogs/insider/AVwebInsider_LSAIFR_207894-1.html about LSA IFR specifically but mostly about the AOI and LSA regulations. He correctly and funnily points out: "This is always amusing exercise because LSA POHs are world-class studies in equivocation. They give the word dissembling a bad name."

The CTLS is already not prohibited for IFR and IMC. The only mistake he makes is presuming the gyros need to be TSO'd. 14cfr 91.205 does not call out TSO'd equipment and LSA, like experimental catagory, is not required to use TSO'd gear with the exception of the transponder and ELT. http://members.eaa.org/home/homebuilders/faq/Equipping%20a%20Homebuilt%20for%20IFR%20operations.html

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In July 2007, a 2006 SW crashed short of Spruce Creek, FL. The pilot said that he pulled the chute and nothing happen. At the time, it was said that he didn't pull hard enough. MAYBE, he did and it wasn't installed properly?

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The chutes and rocket motor get installed here when they come over to the US and the dealers are used to installing these and have done enough to know better so I don't really suspect them.

there were a few and I only saw one of these that was missing a strap. That was one of FD's SB's, to take a look. Mine was one of them.

I think these were A&P's doing the two BRS service bulletins on the 2006-07 CT's. Again it is a case of an A&P not getting the proper education before a task or they would have known what to look for and how it went together. Too many mechanics in our industry (LSA and Rotax) just don't take the time to study and research a task beforehand and from talking to many of them have not and will not spend the time to get the manuals, SB's or education before a task. Before everyone jumps on me, yes there are some good mechanics out there that do the right thing, but there are a whole lot more that don't which has proven itself in the LSA and Rotax areas time and time again.

Then you have some that are detailed oriented and double check all their work and then there are the others that should worry you.

 

It's the mechanic that has those 2 line annual logbook entries and no other paperwork that worry me.

 

Two of the 4 probably would have fired just fine, but the cables weren't attached correctly. One (2007 CTSW) is sitting in my shop as we speak.

 

It isn't FD or BRS's fault because the info has been out there for years. Someone only had to take the time to look. No matter who publishes a technique or how many times it gets published the next new guy on the block who doesn't do the research may still mess it up.

 

Research, read, educate, ask questions from experience, perform the task, double check the task and document well.

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