What’s going on with AADs

Revision 1.1

13 April 2011

Prepared by:

Kirk Smith
Para Concepts
3215 E 1969th Rd.
Ottawa, IL 61350 USA
815-434-6094

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Introduction
Recently, skydivers have been justifiably concerned about incidents with the Argus AAD, in
particular, the effectiveness of the cutter. As an operator one of the 4 Argus Service Centers in
the United States, I have been asked to look into what is going on. I did not expect it to result in
such an extensive study, but it has, and this is the result of the work I have done.

My Background
In full disclosure, I have no direct financial interest in Aviacom, makers of the Argus AAD. I do,
however, operate one of their service centers. Financially, the Argus Service Center is much
less than 1% of my business. The retail arm of Para Concepts sells all three AAD brands
presently available, with plans to carry the fourth brand, when that becomes available in a few
months.

I have been rigging since 1990, and for the last 11 years, I have been a Designated Parachute
Rigger Examiner (DPRE) for the FAA in the Chicago area. My educational background includes 2
engineering degrees from Purdue University, BSEE and MSEE degrees, with emphasis in
software engineering. I have logged 7982 jumps since March 1988. I am an experienced
Tandem (2900 jumps) and AFF instructor (1500 jumps). I am also a Commercial Multi Engine
Land Pilot, with approximately 2300 hours total and 1400+ hours flying jumpers. I have sold the
Cypres, Vigil, and Argus AADs, throughout the years. It has been quite some time since I have
even serviced the FXC Astra or Model 12000, the Sentinel MK-2000, and especially the CAP-3,
Since they are no longer widely in use, I will not discuss those older AAD products in this
analysis. Regarding the Argus AAD, I have worked with Avicaom since its introduction in 2006,
and became one of the first 4 US Argus Service Centers in February 2010. I am very familiar with
the Argus AAD and have a generally high level of understanding of how it works. However, I do
not have direct access to their engineering and technical data, beyond the few items they have
shared with me. I have evaluated all the AAD products, over the years, with great interest and
attention to detail. My background helps me in this respect, but I do not pretend to know
everything. I will try to explain how some AADs may fail under certain circumstances, and
analyze the safety risks with different potential actions. Because I don’t manufacture skydiving
equipment myself, aside from a few accessories, I am the outsider looking in, and I hope this
helps.

What’s going on with the Argus AAD?

Recent History
Four recent incidents, known to me, have raised concerns about the effectiveness of the Argus loop
cutter. The first, a fatality, occurred in Poland, on 25 July 2009. Based on the report of the Polish

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investigators, the Argus AAD was banned in Poland, and soon after, in Australia. Ironically, on 30 March
2011, I was told that the Polish ban had been lifted. I have not independently confirmed this. The Polish
report was to some degree incomplete, since it did not make any representation of component
compatibility, loop condition, and other factors that would help determine what that lead to this
fatality. The photograph that generated the most controversy is below.

The report represented this as the state of the equipment, very clearly, “as found”. I had a
Polish friend confirm the translation. Some question if this could have really been “as found”,
opening up the question of tampering with the evidence. The conclusion of many was that this
must have happened on the ground, since the canopy was still neatly folded. Yet there are
other things to suggest the pilot chute was generating tension, including the condition of the
center of the bag as it was being pulled down under some tension. It is difficult to see in this
photograph, but there were also about 2 or 3 line twists. One could conclude that this
condition was largely generated on the ground, but the question then becomes, what
happened in freefall? The Polish authorities focused on the possibility that the loop was not
completely cut until impact, and developed some evidence about the cutter condition. It is
unclear whether this was conclusive. Other possibilities assume the loop was cut normally, but
that other factors kept the reserve from leaving the container until impact or perhaps just
before impact. The flaps could have locked up similar to the situation in 2004 in Russia on the

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Cypres equipped Mirage containers. The reserve may have been too large for the container,
and if it was, since the main was still in the rig, there may have been insufficient force from the
pilot chute to promptly extract the reserve. The jumper may have become entangled with even
a single line on the reserve, which as I know from personal experience, can cause a reserve bag
lock. I also know from that frightening experience, that clearing the entanglement (perhaps on
impact in this case) can quickly start an otherwise orderly deployment. The report failed to rule
out other causes, and simply avoided addressing them. So it remains to me an unresolved case.
Clearly, a partially cut loop could have resulted in this situation, but several other possibilities
seem equally likely to me, and the report does little to help me conclude anything.

A second incident occurred in Évora, Portugal around September 3, 2010, with a Next student
rig equipped with an Argus AAD. A pre-jump gear check revealed that the AAD display was
blank, and the assumption was made that it had somehow shut off. In reality, it was still
operating independently of the display, and there may have been some glitch, perhaps a loose
connector, that had disconnected the display. On a rapid descent, the AAD activated the
cutter. Now, it is common practice, when descending with a student, to place him or her
seated, back against a bulkhead. It is my understanding that the loop was partially cut, likely at
the intended altitude, since the pilot was descending faster than 20m/s (66 ft/s) at roughly
1000 feet. It is reasonable to expect that the pilot would be pulling out of descent around this
altitude and may have increased the G forces in the cabin. Depending on many factors,
especially in the rigging, the tension can, very easily be removed from the loop by leaning
against a bulkhead. A reasonable scenario was that this was the primary factor that prevented
the clean cutting of the loop. While it is common sense that some minimal amount of tension
improves the efficiency of cutting a loop, the requirement for 10 pounds of tension was added
to the Argus manual (apparently in response to this incident). In addition, a precautionary
bulletin was issued to replace the older cutters. The older cutters apparently are made with a
softer alloy than that used for the newer cutters, which have been provided since August 2007.
It is my understanding that further testing at Aviacom of the recalled cutters, could not get
even a single failure, highlighting the real possibility that the incidents to date were simply due
to other factors.

Then, on Monday, 21 February 2011, everything changed (or did it?). A reserve unexpectedly
opened in the packing room at Skydive San Marcos, shortly after a jump. It was discovered that
the loop appeared to be partially cut, and one portion of it remained attached to the cutter. I
was asked by Aviacom to look into this incident and was part of a meeting on 28 March 2011,
which included Jesus Cavazos of the FAA, Skydive San Marcos riggers Eric Butts and Paula Hunt,
and the rigger that had sealed the rig, Marcus Reed. In addition, Karel Goortz, owner of
Aviacom joined in via telephone.

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In short, the loop appeared to be partially entrapped by the loop cutter as shown:

There were a number of record keeping issues and I attempted to reconstruct the history of the
rig with the rigger that had sealed it. It is likely that this loop did not have silicon applied, but it
is not confirmed due to the lack of good records of who actually installed this loop and the
statement by the rigger that he routinely did not siliconize loops. The damage to the loop could
have happened as the fingertrap was extracted leading to the deployment, or due to reuse of
the loop over several closings. Now, in this case there seemed no factors that could have
reasonably explained this other than a simple failure to cut. Further testing would be
conducted at Aviacom.

Aviacom had attempted to get the equipment for study, but was unable to do so. They asked
for my assistance, and I was able to bring in the FAA to ensure there would be no concerns
about chain of custody, or confiscation of personal property for study. The AAD was received at
Aviacom in Wavre, Belgium at 11:14, 30 March 2011.

Since personally viewing this cutter, I have been made aware of a similar incident in Reggio
Emilia, Italy on 30 August 2010. The details were very similar, except this was in a 2005 Javelin
rig, which opened on the ground, after an apparent activation on a low opening. The details of
this incident are a bit murky, with the rigger claiming to send the AAD to Aviacom for study, but
Aviacom stating that the AAD was not received. I have personally had shipments to Aviacom
delayed for months, but this discrepancy deserves further scrutiny. This incident, as it turns
out, was part of the reasoning for recalling the older cutters.

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In these two incidents, there did not appear to be any other factors, to my knowledge, that
could have caused these “failure to cut” scenarios. The San Marcos incident involved a newer
cutter, and furthermore, it provided the best physical evidence, to date.

What was discovered about San Marcos?

At first, I thought that my observations at Skydive San Marcos constituted fairly complete
information from the physical evidence. There was simply a trapped loop, and I sent the cutter to
Aviacom for further analysis, which I did not expect to reveal many further details. Now, as of 7
April 2011, photographs provided by Aviacom, and confirmed by an independent Dutch rigger,
Arnold Camfferman of Sky Supplies Europe, show metalic debris that was discovered inside the
cutter from this incident:

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The rounded metal piece appears, from the photographs, to be a piece of metal shot from a
weight bag, commonly used in rigging. Mr. Camfferman has concluded that this could easily be
the obstruction that prevented a clean cut. This raises questions about the “smoking gun” that we
thought we had from that incident. I see no reason why a metallic obstruction could not interfere
with a clean loop cut. A portion of a preliminary report reads as follows:

Upon removal of the pinched loop from the bullet cutter, a small metal foreign object fell
out of the cup of the cutter.

The cutter blade also showed a deformation at the place of the loop

The combination of the damaged cutter edge and the foreign object may have
obstructed the complete cutting of the loop, since blade and anvil could not connect
properly and the thermal cutting energy probably was partially lost since the loop
showed no melting marks. The blade could not perform its full stroke and thus not cut
the loop completely .

Conclusion:

The cutter was damaged in use. It is impossible to reinsert the damaged blade back in
the cutter, so this could not have occurded in the factory.

Without the damage, there is no reson why the cutter should not have performed as
designed.

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This newer evidence puts into question any conclusions drawn from the San Marcos incident.
To date, the San Marcos incident has been the most convincing evidence, and now, we cannot
confirm it had anything to do with the cutter design. Certainly, the Italian incident has also
been considered clear cut, from the photographs, even without the physical evidence of a
trapped loop. In that case, the physical evidence is unavailable at this time, for unknown
reasons. To date, I have not seen any shipping documents to show that it was sent to or
received at Aviacom. Without a physical examination of the evidence, however, we cannot
make conclusive statements. I made a significant effort to better document the San Marcos
case, and involved a number of respected riggers and an FAA official to insure that the San
Marcos evidence was without question. Now, in all other related incidents, the current lack of
direct evidence is very disappointing, and raises questions about what action to take, if any.

So,

“What is going on with the Argus AAD?”.

In recent days, I have studied this issue extensively, and based on some testing, I have
developed a better understanding of some general failure mechanisms that might be taking
place. With the lack of relevant physical evidence, it is difficult to confirm, but it does make
some sense. Realistically, I cannot say for sure if there have been any failures, but if there have
been, this analysis goes a little further toward understanding a possible mechanism, and
proposes a working theory.

This is a very hard failure to reproduce. I have not been able to do so, per se. However, I have
been able to reproduce similar results in bench tests, resorting to conditions that I cannot
guarantee are even possible in actual rigs on actual jumps. These worst case tests can explain
the boundary conditions related to this problem. I am beginning to think that the conditions in
a rig are a lot harsher than one would expect. With regards to testing at Aviacom, I fully believe
their statement that there has never been a failure. In some of the YouTube testing videos, I
see that testing has been done on a number of loops at different tensions, and at varied angles
through the loop cutter. In every test I have done under those circumstances, the loop has
been cleanly ejected from the loop cutter. No tension seems to work unexpectedly well under
these circumstances, or unexpectedly poorly, under the worst case circumstances.

So, if it’s not tension, what is it?

Loop tension may be part of the problem, but it doesn’t appear to be the only factor. In looking
at the geometric configurations of actual rigs, I believe one thing has been overlooked, to date,

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perhaps by all the AAD manufacturers in their testing. It is possible that the nearby #0 stainless
steel grommets may pinch the loop or obstruct the hole in the loop cutter or both. The shape
of the #0 grommet is approximately the inverse of the shape of the hole in the loop cutter. The
#0 grommet may therefore be pushed into the cutter far enough to actually interfere with the
some internal parts of the cutter. I have not been able to reproduce significant physical
interference between the grommet and the cutter blade, but it may be possible that the
combination of the pinching of the loop and other dynamics are causing some issues for
cylindrical cutters where the cutter blade is arguably very near the adjacent metal rig
components.

I looked for evidence of this sort of pinching in a rig at Skydive San Marcos that just happened
to be sitting there. I asked if we could open it slowly and see if there were any portions of the
loop that appeared pinched. It took 3 people to carefully peal back flaps and examine the loop.
I was not surprised to find evidence, but I was surprised at just much the evidence showed
significant pinching of the loop. The position of the #0 grommets placed them very close to the
openings in the loop cutter, easily in a position to be pushed down into the hole, and the loop
itself was flattened, as shown in the photos (my apologies about the focus, but the idea is
clear):

Why is this important?

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If we think of the mounting of the AAD in a rig, we find that there are several geometrical
arrangements in use by different manufacturers, in order to accommodate rig design and
provide for the routing of cables. I am not aware of previous statements that the exact
mounting method in a rig could have a significant effect on cutting efficiency of AAD cutters.
Further, some cutter designs may be more or less susceptible to different issues. Not all AAD
cutters have identical designs, and I would not expect every possible failure mode to be the
same for each design, nor occur with the same frequency.

To discuss this, we need to be able to speak of the geometry, and I would like to think of it in
terms of roll, pitch, and yaw, terms that are understandable to pilots and to most people in this
industry. We normally think of a loop that passes straight through the cutter, in a vertical
fashion. While this is never perfectly achieved in rigs, it looks like this:

In Rig Configuration 1, for instance, with an arrangement like an older Infinity container, the
tension, above and below the cutter, pulls the loop in directions perpendicular to the cylindrical
axis of the cutter. The elastic keeper, however, allows the fairly easy roll of the cutter along its
axis. Reasonable tension on the loop will rotate and align the cutter, creating something closer
to the picture above. However, if roll was possible, it would look something like this:

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Consider Rig Configuration 2, like a Javelin or Wings that mounts the cutter side to side and the
next flap with tension is pulling the loop to the side. This is what I am calling pitch. A loop
cutter with worst case pitch looks like this:

Consider yet, Rig Configuration 3 that mounts the cutter 45° to the loop cutter, or mounts the
cutter between 2 flaps that apply tension to the loop at 90° angles. A Mirage or a newer
Infinity would fall into this category. A loop cutter exhibiting this pitch and yaw, and possibly
some roll looks like this:

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I have no doubt that loop cutters of all brands have been extensively tested in many
configurations, but I wonder how much testing has been done, on any brand, with cutters
arranged at these strange angles, with grommets pushed into the cutter holes as shown here:

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 Does Geometry Really Matter?

I am not aware of any cases of suspected failures with the simple geometry of Rig Configuration
1. That is the configuration that is easiest to realistically test, and is best supported by test
protocols to date. Until I saw recent evidence, I was perplexed. But noting that suspected
incidents have all occurred in rigs with Configuration 2 or 3 suggests that geometry could be a
significant factor.

AAD Cutter Construction

There appears to be two basic designs of AAD cutters, in current use. The Cypres AAD has a
linear blade against an anvil. The Vigil and Argus AADs use a circular cutter against a similar
anvil. If you hear about 2 cutting blades, you are likely hearing about the 2 parts of a circular
cutting blade that come in contact with a loop passing across the circle. Each basic design has
advantages and disadvantages, and certain manufacturing details are more important for one
design over the other.

For a linear blade, it is extremely important that the blade is very sharp and the hardness of the
blade and the anvil insure that individual fibers will be cut. It is possible that some small
number of fibers may not be completely cut with this type of cutter, but if the strength of the

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remaining fibers is sufficiently small, the normal tension on the loop eliminates this as a factor.
I have, to date, not observed uncut fibers with this style of cutter, but I expect that it could be
possible, due to a large number of factors. The Cypres cutter is actually very interesting. In my
experience, the plastic material adjacent to the blade actually traps the loop on every firing.
That is, the materials that are used to protect the loop from the blade are propelled towards
the anvil, along with the blade, and can, at least momentarily trap the loop. It is my
expectation, that the plastic materials involved are not able to provide enough force to
permanently trap the loop under most normal circumstances. With limited testing, the most I
have able to reproduce is about a 1 Kg extraction force, something that is no problem in a real
rig, with expected much higher loop forces. In fact, the Cypres manual requires that the loop
tension be a minimum 5Kg, so their requirement most likely eliminates this potential issue. I do
not have hundreds of Cypres cutters to verify this, but as a well respected company, I would
expect that they have done the necessary testing to verify that the plastic insert cannot
sufficiently trap the loop in normal scenarios, and I suspect this is a non issue. However, it is my
intention to raise questions, even if they are not a likely cause of problems. This scenario falls
into that category.

For a circular blade, very near the body of the loop cutter, the efficiency of the cut can be
affected by a large number of factors, which I will attempt to explain. The Argus AAD and the
Vigil AAD employ this sort of cutter, and generally speaking, concerns about one apply to the
other. It is possible that one cutter is manufactured to different tolerances than the other,
either exacerbating or alleviating possible problems. I will leave for others to decide whether
and to what extent manufacturing methods and tolerances can reduce or enhance these
problems. I expect that in light of recent Argus incidents, there will be much discussion about
the Vigil cutter, a similar design, manufactured by a different company. Are the differences
between the two cutters sufficient to eliminate this potential problem or perhaps to reduce its
frequency in the field?

It should be noted that both the Vigil and Argus cutters have been extensively and
professionally tested since their introduction. The Vigil cutter has gone through 3 revisions and
bulletins have been issued regarding replacing the older versions, depending on the rig
configuration. The original Argus cutter was replaced in all rigs following a mandatory bulletin
in early 2007. In both cases, plastic inserts were the primary concern. It would seem that the
plastic was designed to protect the loop from the metal components of the cutter, but in the
field, the plastic could become damaged and rough from normal wear during packing, and
could eventually cause unnecessary damage to the loop. The bulletins required the
replacement of that cutter with one that did not include a plastic sleeve. It should be noted
that if the cutter is located below the pilot chute (such as in a Javelin, Wings, or Dolphin), the
original Vigil cutter is still authorized. In addition, after July 2007, the Argus was shipped with

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an updated cutter, which was very much the same design, except that the cutter blade used a
harder metal alloy, and the stroke was a little longer. So, in the field, we are now dealing with 3
Vigil cutter revisions, at least 1 Cypres cutter revision, and 2 Argus cutter revisions. When the
M2 AAD is put on the market, we will have still another cutter configuration to understand.

On 29 June 2010, Jo Chitty published a very interesting report about the efficiency of different
loop cutter designs. I am not sure of the exact history, but I believe this report was used, in
part, to justify the banning of the Argus AAD by the Australian Parachute Federation. On the
surface, it is not clear why this did not also result in a ban for all brands using a cylindrical
cutter. More recently, this report was published on the PIA web site, as a document related to
similar actions by US container manufacturers. Overall, it makes a lot of sense, and is well
thought out. However, based on actual evidence, I must conclude that the exact mechanism
causing these failures is related to, but not quite the mechanism as stated. I am not implying
that this report made incorrect statements. I have been able to refine some of the details and
show a similar mechanism that is more consistent with the physical evidence and my limited
testing. Jo represents the differences between a linear cutter blade and a circular cutter blade
as follows:

Linear Cutter Cylindrical Cutter

As I understand the design of these two classes of cutter, these pictures represent the
differences very well. The idea is that part of the problem may be that a circular blade divides
its energy across two cuts and may be less efficient. I do not disagree. However, since the side
of the cutter body and the cutter blade essentially form a pair of scissors, this may more than
compensate for these energy issues. It is similar to the difference between cutting a piece of
paper with scissors and using a knife on a chopping block. It would seem that more energy is
required on the cutting block. The report goes on to theorize that individual fibers may be cut
by one part of the cutter at different times than the other part. He shows a picture as follows:

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The evidence from the field is inconclusive, but in some simple testing, I was able to see a
greater trapping effect on the opposite side from Jo’s conclusions. That is, the portion of the
loop that exits the cutter towards the wire is the one that is more easily trapped, according to
available data. We must consider one new effect to show why this could be true.

What is the Scissor Effect?

Everyone knows, from childhood, that the ability of scissors to cut, depend on 2 things, the
tension on the construction paper (or loop in this case) and the angle of cut. Assume the
“scissors” here are an AAD cutter cutting a flexible loop. Even with 1 Kg of tension, a cut
perpendicular to the loop direction works quite well as shown:

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If you want to get a little more efficient cut, you can pitch the scissors in the better direction,
and you will get a similar result:

However, by pitching the scissors in the other direction, you will get an increasingly less
efficient cut, trapping fibers, as shown:

If the cylindrical cutter and the cylindrical body are acting as scissors, you will note that as you
pitch the cutter or equivalently the loop, the efficiency of one side improves in a small way, and

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the efficiency of the other side is degraded, depending on the angle. In general, the efficiency
of the cutter is kept at a reasonable level, even taking these effects into account by the tension
on the loop, and tight manufacturing tolerances, so:

What might take tension off the loop?

At least three effects seem to be capable of reducing the tension of the loop as it passes
through the cutter. Even though the loop tension at the pin may be sufficiently high, after it is
pinched by several grommets, especially for non-siliconized loops, tension at the cutter may be
significantly reduced. The San Marcos and Italy incidents apparently happened during main
deployments, which can impose high G forces over short periods, affecting loop tension in
unpredictable ways. In addition, the effect of recoil or rebound when the cutter bullet is fired,
can move the cutter body over a very short time frame, with the net effect that tension is
momentarily removed from the loop, in relation to the moving cutter body. Let’s consider what
this recoil action looks like:

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If you consider that individual fibers in the weave are at angles to the lengthwise direction of
the loop, you will note that some of them are lined up in the perfect angle to reproduce the
“scissors effect”. In this diagram, we would expect the scissors effect to reduce the
effectiveness of the cut at the top of the cutter, and slightly increase the efficiency at the
bottom of the cutter. This is consistent with all the evidence to date.

What about the thermal energy?

Both the Argus and Vigil AADs claim their cutters generate enough heat to melt any possible
trapped fibers, and yet, I have seen a loop from an actual Argus cutter that did not look like it
was melted at all. I suspect this is another case of testing being done in conditions different
that reality. I too was able to get loop material to melt, in isolation, on the ground. But I did
not try it after a 2 or 3 minute wing suit flight in cold air, with 2 adjacent #0 grommets acting as
heat sinks, spreading the thermal energy across 3 chunks of cold metal. It was winter in San
Marcos, after all, with a high temperature of 25° C (77° F) and a low of 2° C (35° F) on the
ground. At altitude, it is often much colder. As it turns out, the larger metal pieces that I used
to simulate a pinching grommet in my tests would act as a better heat sink at room
temperature, having roughly the same effect as cold #0 grommets.

What can be reproduced?

In attempting to better understand this situation, and develop evidence to either confirm or
refute this theory, I have been able to trap a small number of loops under extreme
circumstances. It is unlikely, but perhaps possible, to experience momentary zero tension on
the loop in an actual rig, but I have been only able to reproduce failures with a similar
appearance by using a completely slack loop, and obstructing the hole of the loop cutter by a
piece of metal that is dimensionally very close to a #0 grommet as shown here:

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I conducted this same test, with and without siliconizing the loop. In the case of the non-
siliconized loop under no tension, on one of 4 tests, the loop became severely entrapped. After
applying 40 lbs of tension, I could not extract the loop. However, in the other non-siliconized
cases and in the siliconized case, still under no tension, I came up with situations that more
closely matched the evidence in the field. The entrapment looked like the following:

In the case pictured above, In order to extract the loop from the efficient side, it took less than
2 pounds (1 Kg) of force. From the side predicted by the model to be a less efficient cut, it took
6.5 pounds (3Kg). In the 3 cases where I could reproduce something similar to evidence in the
field, the prediction of the good and bad sides was proven true. In the end, by removing all
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tension from the loop, and severely obstructing the loop cutter, I was still unable to reproduce
a condition that exceeded the manufacturer’s requirement for 10 lbs or 5 Kg on the loop, as
long as the loop was siliconized, but I came close. The two ends of the loop show the difference
in entrapment under these extreme conditions:

It should be noted that the application of silicon was not originally intended to solve any issues
with cutting. It would seem, however, it may in fact have a significant effect on the efficiency of
this style of cutter. In most of my tests, I was unable to reproduce any significant problems. But
in the case where I could, without silicon on the loop, the details are very interesting. I wish to
state that these tests should not be considered statistically rigorous. I only had a small number
of cutters available for testing, and more extensive tests should be conducted by Aviacom or
independent testers. This falls short of a proof, but could be a very good working theory.

The current working theory is that this type of cutter is capable of a failure mode related to
some combination of the following factors:

• Geometry of the loop in relation to the cutter

• Geometry of nearby grommets in relation to the hole in the cutter
• Forces applied to nearby grommets by the pilot chute spring and flap tension
• Loop tension, or lack thereof

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 • Application of silicone to the loop, or lack thereof
• Exact manufacturing tolerances of the cylindrical cutter blade and the cutter body

The exact combination in any particular incident is very difficult to determine.

Risk Analysis and Comparison of Possible Courses of Action

First, I would like to comment on the 3 Rig Configurations, as described. To date, there is no
evidence that Rig Configuration 1 has ever experienced any incident, in testing or in real life,
nor does the working theory have any likely failure mode for Rig Configuration 1. With Rig
Configuration 2 and Rig Configuration 3, however, there is a failure mode, consistent with the
working theory, which may trap the loop. My working theory shows that there is a “good side”
and a “bad side” of the loop cutter in these configurations, and one can expect entrapments to
occur on the bad side, in real life scenarios. The good and bad sides can be determined merely
by the geometry of the particular cutter installation, in a given container design.

In an optimal cutting configuration, the loop would be at 90° to the cutter cylindrical axis, and
Rig Configuration 1 ensures this. If you believe this working theory, and consistent with all
evidence to date, the safest action for harness systems considered to be Rig Configuration 1, is
no action at all, since there is no expectation of a problem. All else equal, it would be best if
every rig could be configured in this way, but other factors make that impractical. This
configuration likely provides for the most efficient cutting of loops for all cutters on the market,
and is consistent with common sense use of knives and scissors in everyday life. The risk of an
incapacitated jumper without an AAD should be weighed against the risk of something that
appears to be configured like the many cutters that have been successfully tested.

In Rig Configuration 2 and Rig Configuration 3, it is sometimes possible to arrange the flap
closing sequence in such a way to eliminate the effect in the working theory. As examples, if a
Javelin is closed left side flap first and the Wings is closed right side flap first, it is expected that
that would eliminate this effect. That is, the “bad side” of the cutter faces the backpad in an
inconsequential position. If I have correctly identified the mechanism causing this problem,
then these configurations would pose no threat. The failure mechanism can be eliminated by
simple packing instructions. In some packing instructions, for example, the rigger is directed to
“close the side flaps, in turn”. A bulletin could require a particular sequence to resolve or
improve this issue.

Now, there is a class of harness container systems, where there remain questions about the
effectiveness of loop cutting with this style of cutter, and there is no easy alternative resolution.
The question then becomes, what is the safest course of action? Further, there will be some
that are skeptical that this analysis has correctly identified the exact mechanism, and would like
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a logical argument independent of this analysis of the evidence. There is, then, a different
approach to risk analysis that does not rely on my working theory. In this analysis, harness
container systems are divided into categories based on the expected result of a “failure to cut”
scenario, however likely or unlikely, and this risk is ultimately compared to the risk of jumping
without an AAD.

Rig Configuration A is a rig where the cutter is placed below everything in the reserve, at the
farthest point from the ripcord pin. In these configurations, the extent of the risk is this: If you
are unable to extract the ripcord pin, and you have already arrived in freefall at the altitude
that the AAD is designed to activate, there is some small chance the AAD may not cut the loop.
If you manually extract the pin, there is no physical mechanism where the cutter can cause a
problem. Examples of this rig configuration are the Javelin and the Wings. For Rig
Configuration A, the issuance of a bulletin requiring the removal of an AAD that will likely work,
opens up the real risk that a jumper who has removed the Argus AAD, might be rendered
unable to manually open either canopy, and die simply because of the removal of an AAD. In
the case where the AAD does not work as expected, there is nothing in the rig design that is at
fault. Rather than issuing a bulletin requiring the removal of a particular brand AAD, would it
not be better to educate the jumper about the possible risks? In that situation, the jumpers
with financial means may decide to use an alternate brand, at least until the issue could be
better understood and resolved. If there are rigging changes (such as flap closing sequences)
that can minimize or likely eliminate this problem, then the bulletin could require those
changes. There has been much said about the possibility of the delayed launch of the reserve
pilot chute, perhaps on the next load, at an inopportune moment, while climbing out, for
instance. Rather than using this as a basis to require the removal of a device that is largely
effective, with 24 saves to date, I would think this would be an opportunity to remind jumpers,
in the same bulletin, to do a thorough gear check before every jump, and if the AAD reports
“Replace Cutter”, as shown on the display of the San Marcos cutter, do not jump the rig. In my
opinion, some of the recent Argus bulletins could be addressed in this alternate fashion, and as
a result, increase the safety of jumpers. I dread to think about the first jumper that gets
knocked out on a jump and goes in, simply because they removed their AAD due to one of
these bulletins, and decided to jump without an AAD while this issue was being sorted out. This
is an example of a decision that may have unintended consequences. However good the
intentions of the container manufacturer, to me, the flip side seems to carry more risk. I
respect the opinions of all the manufacturers, but I must respectfully disagree with some in this
case. I believe that such bulletins create more risk than they resolve.

Rig Configuration B is a rig where failure of the loop cutter to cut will not restrict the reserve
pilot chute from coming out with a normal activation, but could bind the freebag in the rig. An
example of this is the Vector III, among others. Towing a reserve pilot chute is a frightening

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prospect, and it is understandable that this possibility generates such concern. If we consider,
however, that all AAD cutters may impose some amount of restriction on the extraction of the
loop, we should try to estimate the maximum extraction force, and compare that to the
expected force of the reserve pilot chute. For example, in any rig, the force required to extract
the freebag is the weight of the freebag (7 to 13 pounds or 4 to 6 Kg is typical for a sport rig), so
we expect a normal pilot chute to provide extraction forces well beyond those numbers. In a
presentation given by Bill Booth about the Skyhook RSL, he noted that the requirement to hand
tack the Skyhook to the bridle cause much concern and heated discussion. Seal thread is
required which produces roughly 3 to 5 pounds (1.5-2.5 Kg) of breaking force. In practice, I
have been told that the Skyhook tacking has measured as much as a 15 pound breaking force.
Bill Booth went on to say that they had tested the Skyhook with lite tack (approximately 50 lbs
(23Kg) breaking force), in order to insure a careless rigger could not cause a problem, and they
were happy with the results, which indicated no delay in deployment. So, if the pilot chute is
out, we can expect forces far in excess of what we understand a few trapped fibers might
produce on an AAD cutter. So, if you believe my working theory, and you believe Bill Booth in
his analysis of the Skyhook tacking, the risk factors are very similar to Rig Configuration A. An
AAD with a largely effective cutter is better than no AAD at all. I would like it if rigs that fall
under Rig Configuration B would not require any bulletin that goes beyond educating the
jumper about the situation, reminding jumpers to do a full gear check before every jump, and if
the AAD reports “Replace Cutter”, do not jump the rig. If there are other geometrical factors as
discussed, that could be addressed, as well. Because it could trap the freebag under extreme
circumstances, I understand how manufacturers might be nervous, but the other factors I
mentioned seem, in my mind, to favor keeping largely effective AADs in service. The relative
risk of each of these factors is open to some debate.

Rig Configuration C would apply to any rig with the cutter above the pilot chute. A trapped loop
could keep the pilot chute from launching, and result in a total malfunction. Depending on the
exact entrapment, manual ripcord activation could be disabled. The Mirage is one example of
this configuration. If you believe my working theory, you could conclude that the Argus cutter
in a Mirage, if it should fail, is more likely to fail in a way that would allow a manual extraction
of the ripcord and the clean launching of the pilot chute. That is, the risk of entrapment largely
exists between the cutter and the number 3 flap. Extracting the ripcord pin would result in a
clean launch. This is the scenario found in San Marcos. It is not clear how many rigs have this
arrangement of the cutter and adjacent flaps, but it is clear that this configuration will affect
the risk analysis to a much greater degree. For a rig where a failure to cut can inhibit manual
activation, it is difficult to balance the risk of a failed cut with the risk of a late or missing
manual activation. The risk of both of these scenarios is real, but it is not clear which is more of
a threat. Again, geometrical factors that could be addressed by otherwise inconsequential flap
closing sequences could be addressed in a service bulletin. It is expected that the risk analysis
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will show that issuance of a bulletin might very well reduce risk over the alternative. Since it is
not clear exactly what is going on, relative risk factors are not well known, and I expect varied
opinions.

Recommended Course of Action

In the end, my primary concern is safety. I recommend reviewing recent service bulletins, to see
if, in light of this new information, there is a safer path to take. It is interesting to note three
manufacturers in Configuration A have all taken different actions. Makers of the Wings rig have
not issued any bulletin. A bulletin was issued for the Dolphin. Five days later, upon further
consideration, they decided to rescind their bulletin. The makers of the Javelin have stood by
their bulletin. I believe everyone is trying to do the right thing, but there is real disagreement,
even by container manufacturers about the best course of action.

Another position was taken by Basik Air Concept in which they said, in part:

Basik Air Concept hereby strongly advises all owners of Advance and Seven Harness /
Container Systems of the fact that we cannot take responsibility of the interaction of any
AAD with our reserve container, generated by the means of such AAD by cutting the
closing loop inside the container.

This responsibility lies solely with the AAD manufacturer, who has to provide proof to his
customer, that his product does not negatively affect the tested and certified functions
of an Advance or Seven reserve container.

Many manufacturers have not published any statement or bulletin, and de facto, taken this
stance. This is actually a very nice way to put things and the way I would like to see this issue
understood. It is unreasonable for a container manufacturer to be an expert in every facet of
AAD manufacturing and operation. Therefore, why should they be expected to provide
approval based on anything other than physical compatibility?

Some manufacturers, however, feel it is their responsibility further evaluate AAD products. In
light of further information, some of these bulletins could be rescinded, and in other cases,
Aviacom could develop and test alternate solutions. One possibility is an inexpensive sleeve
that could slide over the cutter, which would restrict the direction of the loop at the mouth of
the cutter to roughly 90° to the cutter blade, while prohibiting nearby grommets from entering
the mouth of the cutter. Because of extensive testing in this geometrical arrangement, and
with a new series of published test results, this could become the basis for rescinding bulletins
for even the most challenging rig configurations. I would expect that Aviacom could then take
some time to develop further refinements, perhaps a newer cutter that would likely eliminate

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concern about these issues, altogether, by design, as these issues become better understood
through lengthy testing. In the mean time, skydivers could jump with an Argus installed, a
much safer configuration than no AAD at all.

The problems with the Argus AAD are not in isolation to other issues with AADs. The next
section of this report will raise questions concerning other products. This is not intended to
suggest that other products should be immediately grounded. In contrast, I hope that this
discussion will put the Argus AAD problems in perspective, and allow a more rational discussion
of the issues.

What’s going on with the Vigil AAD?

The Vigil AAD has been on the market a few years longer than the Argus AAD. Like the Argus
AAD, they have issued multiple bulletins about their cutters. The concern, in their case, was not
based around scenarios where they might not fully cut, but were related to damage that could
be caused to the closing loop that might result in a premature deployment.

In my opinion, there are 2 open issues with the Vigil AAD that cause me some concern. First,
the cutter design is very similar to the Argus AAD. In my mind, it is not clear why there have
been no reported incidents similar to the ones that have caused the recent concerns with the
Argus AAD. It is quite possible that different manufacturing techniques with different resultant
tolerances may reduce some of the effects we see with the Argus cutter. It is also possible that
the installed base of the Vigil AAD is largely in rigs that do not produce this effect. Again, it is
not clear if this cutter has been thoroughly tested under the circumstances that I now
understand to exist in certain rigs. I look forward to an official test report showing the
effectiveness of the cutter in situations that have, for the most part, been proven to occur in
the very similar design in the Argus cutter. In a short email, I requested a few Vigil cutters for
my own testing, but I was assured that the Vigil cutter would not exhibit similar failures, and
was sent a test report. Since the information about geometrical issues in rigs is a new
consideration, the report did not address them. These new theories require revisiting the basic
assumptions and reevaluating the design and manufacturing parameters. I would welcome
interaction with the Vigil technical team to share knowledge about my investigation.

My larger concern is with another, apparently unresolved issue with the Vigil AAD. I had hoped
to see a more thorough response to the issue of unintended activations. According to the US
National Transportation Safety Board, in their DEN08FA078 report, a Vigil AAD was implicated
in the 19 April 2009 incident in Mount Vernon, MO, including the crash of a Cessna 206, the
death of 2 jumpers, and the serious injuries to the pilot. While arguably in level flight, a Vigil

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equipped jumper climbing out, experienced a reserve activation and subsequent fatal
entanglement with the tail of the aircraft. One Cypres equipped jumper remaining in the plane
also died, and the pilot was severely injured. It should be noted that the Cypres did not
activate.

More recently, in the summer of 2010, I received a correspondence from Advanced Aerospace
Designs (AAD), the makers of the Vigil AAD, regarding an incident where a Vigil 1 and a Vigil 2
AAD both activated in an aircraft in level flight when the door was opened. In the end, they
concluded that activation parameters had been met, and cautioned against opening the door of
an aircraft in the activation range. This puts into question, what is the best course of action in
an emergency situation in the activation range, where a bail out would be otherwise indicated.
With this statement, I fully question the choice of activation parameters on the Vigil AAD.

In this case, I had hoped that Advanced Aerospace Designs would issue further statements, and
likely follow up with a firmware update, that would prevent this particular scenario from
happening again. To this date, however, I have not received a convincing explanation as to why
this sort of incident will not occur again. A friend of mine was recently prohibited by the pilot
of a helicopter in Sebastian, Florida, from boarding with his Vigil AAD turned on, due to a similar
incident there over the recent winter holidays. One wonders whether there are other
incidents, which have not come to my direct attention.

Each AAD product has selected different activation parameters, based on their understanding
of what is more likely to save someone versus what is more likely to result in a problem. The
decision process within each AAD is complex and subject to much variation, depending on the
opinions of the designers. It is difficult to say that one algorithm is superior to another. All can
fail to do the right thing in extreme circumstances. As a software engineer, I understand the
difficulty with the fire/no fire decision. Air pressure, and thus altitude data, is extremely noisy,
and affected by numerous factors other than just altitude. The reliable computation of the
descent rate is even more difficult. It is my opinion that the firmware in the Vigil AAD (both
versions) is too simplistic, and will continue to activate the cutter in situations that may be
unsafe for the jumper and other occupants of the same aircraft, including the pilot. I welcome
a full discussion with Advanced Aerospace Designs about this issue, and their limited response,
to date, has been simply disappointing.

The various bulletins about the Argus AAD raise the question why this Vigil issue has remained
“under the radar”, so to speak. It would seem to me, as a rigger, jumper, and especially as a
jump pilot, that this is a greater concern than a cutter that might not work in rare
circumstances. This issue could jeopardize the safety of an entire aircraft, when everyone is
otherwise following the strictest safety protocols. Now different people will have different

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opinions of the severity of a particular problem, but I find it hard to understand why this
particular concern is not receiving at least as much attention as the Argus cutter issue.

What’s going on with the Cypres AAD?

The Cypres AAD has been on the market much longer, with an introduction in 1991. Airtec has
not been without issues along the way. Recently, Airtec has claimed that their product has
“always worked”, but I find that unsatisfying. Many years ago, I watched a Cypres AAD activate
a reserve when an instructor keyed up his student radio. This Electromagnetic Interference
(EMI) issue has long since been resolved. In 2003, I was involved in the investigation of an
incident at Skydive Chicago where a jumper who had been knocked out in freefall was found
dead on the ground, with just his reserve pilot chute out of the rig, with at most a few feet of
bridle extracted. Airtec was convincing in saying that their product had activated at the correct
altitude, but some external influence had kept the reserve from opening. When I was recently
asked to look into the details of the Polish Argus incident, I naturally compared the details of
the 2 incidents. I found the details from 2003 to be a much more convincing argument that
some sort of delayed cut had caused the incident. I was surprised that the Polish incident more
easily resulted in that conclusion, with much less evidence. Recently, I interviewed a reliable
eye witness to the 2003 incident, and he again confirmed, “based on what I saw, there is no
way that the pilot chute came out of the rig before impact”. That is not to say that the Cypres
cutter failed to cut. However, the official resolution of the 2003 incident certainly affected my
interpretation of the Polish Argus incident. In the 2003 case, there was little attention, no
bulletins or groundings, and not much to say about a fatality that was officially “unexplained”. I
got the impression that I should keep the details confidential, lest people become too
concerned about AAD technology to use one. In contrast, in 2008/2009, the uproar about the
Argus incident was much different, and in my mind, put people at unnecessary risk, jumping
with no AAD because of the various bulletins.

More recently, on 26 December 2008, a jumper in Perris Valley, California apparently made no
attempt to deploy a parachute, and yet her Cypres AAD fired, without saving her. I understand
that this event is the subject of a lawsuit against Airtec. Just on 25 March 2011, while I was
starting to study the San Marcos incident in detail, a jumper at Cross Keys in New Jersey made
no attempt to deploy a parachute, but his Cypres AAD was unable to complete the opening of
his reserve in time. This is the basic reason that the name of these devices was changed, many
years ago, from Automatic Opening Device to Automatic Activation Device. They attempt to
activate the reserve, but the opening is too much to guarantee in a name.

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In a recent conversation, Dave DeWolf told me that he is aware of 16 cases where an AAD
activation was insufficient, for whatever reason, to fully deploy a reserve in time, resulting in 16
fatalities. He said that he believed this was the most significant unresolved issue in the AAD
world today. It would appear that this is not a new problem, and is probably not limited to one
brand of AAD.

These incidents, on the surface, can be quite disturbing. However, in the 3 cases I am familiar
with, the jumper failed to manually deploy the parachute. Whatever the complications in
getting the parachute automatically deployed, it is unreasonable to blame the AAD. Some
reasoning provided in Argus bulletins simply state that they are questions as to whether the
product will work properly. In consideration of these Cypres incidents, one could make the
same statement about the Cypres AAD. However, I think most people would agree that
grounding the Cypres AAD would put many more people at risk than keeping it in the air. These
examples have been provided to better put into perspective the recent Argus bulletins, and to
argue that there may be a safer course of action.

Now, in the end, I hope we can have some discussion about the selected activation altitude of
AADs. The choice of 750 feet (229 m) on the Cypres AAD was made before the advent of free
flying. It should be noted that the Vigil AAD has chosen 840 (256 m) feet, and Argus AAD has
chosen 820 feet (250 m), slightly more conservative choices. Are these differences enough to
make a difference? Perhaps, in a few cases, but I would not expect in a general way. Perhaps it
is time to reconsider the activation altitude in conjunction with the recommended hard deck for
jumpers of different experience levels. It is my opinion that the normal AAD activation altitude
could be raised to 1000 to 1200 feet, if the recommended break off and main opening altitudes
were raised by 500 feet, across the board. These changes would result in a safer environment
for everyone, with a relatively small cost in lost freefall time.

What’s going on with the M2 AAD?

According to their literature, we will soon find out. I have sent an email to them, willing to
discuss these issues, and I hope they will consider the recommendations of this report in their
imminent product launch, which is expected to be in the next month or so, as I understand it.

Executive Summary – The Argus Issue

This report has covered a number of varied topics. To better put the Argus cutter problem in
perspective, I would like to back up a reasonable distance, and summarize the analysis of that

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issue, in isolation of other AAD issues. This is, after all, the concern that started this research
project.

Essentially, the risks of issuing bulletins essentially grounding the Argus AAD should be
compared against the risks of skydivers jumping without an AAD installed. There are some
skydivers, with seemingly unlimited resources, that could install a product from a different
manufacturer, but it is not clear if this is a significant portion of the market, and indeed, if this
will even improve the situation.

With the recent Argus issues, there are two primary concerns here:

1. How likely is the Argus cutter to trap a loop?

2. What are the consequences of a trapped loop?

How likely is this Argus cutter to trap a loop?

The first question relies on the knowledge of the exact failure mechanism. For a Category 1 Rig,
for instance, an older Infinity or a Vector III, the loop is aligned perfectly with the cutter, and
one would expect the reliability of the cut to be very nearly the same as in thorough testing at
the factory (100%). With this expectation, it is probably inaccurate to say that a jumper is safer
without an AAD, than with one that has been thoroughly tested in the conditions expected in
this particular configuration.

In contrast, when the geometry complicates the issue (Category 2 & 3 Rigs), it is difficult to give
an exact percent of confidence in the system. For instance, since we believe that we have seen
a failure in a Javelin, we would have no reason to conclude that it couldn’t happen again.
However, with better confirmation of my working theory, and requiring the closure of the left
flap first, we could reasonably conclude that the likelihood of a consequential future failure
could be reduced to very near 0%. The worst case is that it would have no ill effect. Based on
the results of my limited testing, you may have some new information to influence your
decisions. Despite the uncertainty, I would hope your expectation of a failure could be close
enough to 0% or 100% to make good choices. That may take a little more testing.

What are the consequences of a trapped loop?

The second question is easier to quantify. Rigs are divided into at least 3 categories:

A. A trapped loop has no effect on manual operation.

B. A trapped loop would not inhibit the pilot chute, but could restrict the freebag.
C. A trapped loop could restrict the launch of a reserve pilot chute, and a subsequent
manual activation may or may not allow the pilot chute to launch.

It would seem that the resolution of these varied scenarios is much different.

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A. A trapped loop has no effect on manual operation.
In the first case, I would argue that grounding will force some people to jump with no AAD,
rather than one that is largely effective. In my opinion, I simply can’t justify a ban of the Argus
AAD in this type of otherwise safe configuration. In order to protect people from a delayed
deployment, I would simply issue a bulletin requiring a thorough gear check before each jump,
with emphasis on checking the AAD display for a non-normal status such as “Replace Cutter”.
This is no different than the normal recommended pre-jump gear check that we teach our
students in the program that I co-authored at Skydive Chicago.

B. A trapped loop would not inhibit the pilot chute, but could restrict the
freebag.
In the second case, it is a very gray area, depending on the amount of expected entrapment,
the expected extraction force, and the expected force applied by the reserve pilot chute. Based
on my current understanding, I expect the reserve pilot chute to win over any expected minor
entrapment, and my best recommendation is to jump with that configuration rather than
without an AAD. This is difficult to confirm 100%, but it does correspond with the expectations
from my limited testing. I understand where people could have different opinions of this, but I
think the evidence to date is at least consistent with my conclusion.

C. A trapped loop could restrict the launch of a reserve pilot chute, and a
subsequent manual activation may or may not do anything.
In the last case, however, it is difficult to recommend continued use of an AAD that could cause
a total malfunction. In the end, however, it is really just a comparison of the statistical
likelihood of being incapacitated and the statistical likelihood of this failure mode. This is a very
muddy decision, and hard to say what is right or wrong. One could easily say that everything is
wrong about this case.

I hope this meta-analysis and summary of the Argus issue helps in the decision making process
of both jumpers and harness-container manufacturers in this current industry crisis. Despite
efforts to seek black and white places, the consequences of these decisions often end up in a
gray area, with many unintended consequences. I hope these comments can result in a more
informed decision process and better discussion in the industry.

Related Issues

I am concerned about poorly documented and difficult to explain incidents becoming the basis
of restrictive service bulletins in the skydiving marketplace. As long as a company is willing to
work towards resolving incidents, I would prefer bulletins be issued, raising awareness about

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the issues in progress, but not be so strong, in general, to restrict the use of other company’s
products. In the case of Aviacom, I believe, albeit with very good intentions, a number of
companies have set a precedent on an action that has resulted in a coordinated grounding. In
addition, part of the published basis of the grounding was a report regarding these issues from
Jo Chitty, which I found to contain some statements inconsistent with some of my own studies.
I am worried as to what is the next such action. I value the variety of companies in the
skydiving equipment marketplace, and hope that this sort of action does not limit competition.

In the AAD market, for instance, Airtec has taken the position that canopy swooping can be
addressed by higher limits on descent rate in their Speed Model. Aviacom has taken an
alternate position in their Swoop Mode, where a successful main opening will inhibit further
reserve activation on that jump. Neither approach is completely right or wrong. An unintended
activation during a swoop is widely considered to be fatal, and it has proven to be so. Opinions
do vary greatly about how to prevent this. A robust marketplace allows the jumper to select the
product that best addresses their own individual needs and opinions, and their perceptions of
the best algorithm and the best implementation of that algorithm in the marketplace. Further
similar bulletins may shrink the marketplace and make it prohibitively expensive to even
attempt to enter the market. This could have wide ranging implications for the skydiving
industry.

Questions about Legal Authority

Several companies have now issued service bulletins which all seem to follow a boilerplate from
the PIA technical committee. The basis of the bulletins relies on the authority granted by 14
CFR 65 with wording as follows:

Because of this cancellation of the approval of the installation of the Argus AAD in
<Insert Manufacturer Here> products, it could now be a violation of 14 CFR Part
65.129(e) if a certificated parachute rigger were to pack a <Insert Manufacturer Here>.
harness and container system with an Argus AAD installed. It could also be a violation of
14 CFR Part 65.129(b), if, because of the installation of an Argus AAD, a parachute were
to be deemed by the FAA to not be safe for emergency use.

The actual regulation, 14 CFR Part 65.129(e) and 65.129(f), reads:

No certificated parachute rigger may (e) Pack, maintain, or alter a parachute in any
manner that deviates from procedures approved by the Administrator or the
manufacturer of the parachute; or (f) Exercise the privileges of his certificate and type
rating unless he understands the current manufacturer's instructions for the operation
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 involved and has— (1) Performed duties under his certificate for at least 90 days within
the preceding 12 months; or (2) Shown the Administrator that he is able to perform
those duties.

Then the service bulletins go on to say:

All users of an Aviacom SA/NV Argus equipped <Insert Manufacturer Here> harness and
container system should remove the Argus AAD from their system, prior to making ANY
further jumps with the system.

It would seem that the FAA regulation never gave authority for the manufacturers to demand
any action by the individual jumper. The only authority is granted over the rigger doing
maintenance. The requirement to do anything prior to making “ANY further jumps with the
system” is clearly beyond the authority granted by the FAA regulations. It would seem that this
regulation was never intended to permit this sort of directive. This brings into question the
validity of the bulletins that have been issued.

As I read the regulations, jumpers are permitted to continue jumping with their Argus AAD until
their rig requires service, for whatever reason. This is different than the impression created by
the bulletins issued by several manufacturers.

Conclusions?

Each individual skydiver and each manufacturer in the skydiving industry will find something in
this report to agree with and likely something to disagree with. If you are really upset, I
encourage you to take a deep breath, and read the report again. It is my hope that this report
will result in more reasoned discussion about the best course of action around some recent
incidents. I hope that you will see the logic in understanding the issues with the Argus cutter,
as I have presented them. I fully expect that this explanation will not be sufficient for everyone,
but I hope that the details presented about the Argus and about other AAD products will direct
further discussion into a better understanding of …

what’s going on with AADs.

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