action: motor certification

Technicaly a proprietorship could do it (or any corporate form), so nothing at all except equipment, a procedure manual, customers. I would gladly provide a draft manual for the entity to edit and adopt, equipment for testing, two customers minimum.

Currently NFPA standards are the standards, so whatever samples are requested there must be tested. The entity should seek to be a listed party (AHJ) with NFPA, a designee for NAR and TRA if they would agree to such a thing (which only NIH attitude would prevent), and seek a treaty for cross-recognition of certs with TRA/NAR/CAR/UKRA and others. In the past such treaties have not been unreasonably withheld but considering why this proposal is needed in the first place I would not be surprised if you ran into recalcitrance to maintain the monopoly of fraud and deceit and market non-access to new legal vendors. It was my being verbally notified to EXPECT that (at TRA, at NAR, at NFPA meetings controlled by NAR/TRA/AT/Quest/Estes) that I did not just form my own personal AHJ years ago.

Jerry

Definitely. But obviously I could not be the person in charge for political reasons and I could not be the only customer or rejection would be guaranteed.

They have stated they do not intend to and the consensus among board members and typical members is that is just fine.

So far.

I predict it will stay that way.

Jerry

This should be in the FAQ.

Hard proof the interests of the members are NOT the goal of TRA, but the interests of the entrenched vendor AeroTech.

They would rather wait 2 years for Aerotech to partially recover than rush certs for CTI or allow renewal certs for USR.

CTI motors were in TMT testing at the time of the fire, for example.

Jerry

No such pressure exists.

Evidence: consumer shipping of motors from person to person.

Unless Fred Wallace somehow thinks that is legal like the allegedly (alleged by Fred Wallace) non-commercial-carrier USR motors Ken at PH carries around allthe time.

Ken told me he got specific permission from DOT to carry those. True or false?

He also said he got specific permission to ship them for return, I offered to prepay Ken to do so and send whatever boxes needed and he failed or refused.

And also didn't pay his bill.

Great guy, eh?

Jerry

I is too literate.

Jerry

Yes, the authorities set the legal requirements for manufacturing and shipping of motors. These include an LEMP and DOT permits, at least for solid-fuel motors, correct? (I don't know what permits would be needed for manufacturing hybrids.)

Seems to me they can set whatever standards they want as long as they don't require or approve anything that is against the law. What permits or licenses does TRA require that the law doesn't?

Nope.

Motors are exempt per 27 CFR 555.141-a-8.

Classifications.

None.

But TRA won't certify them from Jerry anyway!!!!!!

Which is PRECISELY what they do.

Motors are exempt per 27 CFR 555.141-a-8.

ATF (all PADs exempt) Business license (many areas exempt) DOT in a particular name (DOT only requires the material itself is classified and do not care who sells it.)

So, Izzy,

Would your "new TRA" answer questions like I asked you about ARSA, or not?

I find it so very interesting that you won't answer even the most basic questions about ARSA, even though you are the "communications facilitator" (your term) for ARSA.

- George Gassaway

----------- repeat of questions that Izzy refused to answer

Izzy,

I?ve had some problems locating some things on the ARSA website.

Where can I find the ARSA by-laws?

Where can I find any information as to when/where ARSA was officially created as regards public/state (or federal?) documentation or recognition?

Where can I find info on when the last ARSA election was held, and who ran?

Where can I find info on when the next ARSA election will be held?

Where can I find a list of who is on the ARSA board, which positions are held by what people, and how does the ARSA board operate if for some reason the ARSA by-laws website link didn?t load?

As ARSA communications facilitator, I?m sure you won?t mind answering these.

- George Gassaway

good answer

- iz :)

David We> Ismaeel Abdur-Rasheed wrote:

good point!

the purpose of a motor certification as performed by a rocketry organization is to establish some confidence the motors safety and performance, something that is impractical for a individual buyer to do

but a buyer and seller do not need a national organization to police shipping protocols.

- iz

Duane Phillips wrote:

Ted Cochran and Ken McGoffin made some excellent posts to ROL about the challenges of compliance with ambiguous or conflicting regs from a myriad of AHJs (under the topic "Issues with NAR" Nov 28-29th)

I think that by the time you figured out what 100% compliance looked like, it would have already changed. Unless you can afford to be involved in the revisioning of all regs in all AHJ's ongoingly.

but there is that notion of "substantial compliance" Jerry had mentioned

the situation I gleaned from JC's communications to me was that he was blindsided by state regs, tried to get handle on "regs in general" from TRA, and observed that they hadn't been taking any responsibility for understanding (let alone complying) with even the federal regs. In his view, that was reckless and put members at risk

there has to be some level of 'best effort' to comply with federal regs, and then have state (and local) compliance investigated by local clubs

for example, in doing my LEUP research, I found that the Dept. or Labor in New York State is the AHJ for explosives, and has its own permit process (complete with background checks). Thats in addition to the SFM. But in New York City, NYC ordinances superede even those!

how is a "member" to know? is his faith in an organization misguided when he looks to them for answers? Is it that unreasonable to expect that a national organization (perhaps through cordination with local clubs) have a handle on state regs (as a minimum)?

but a newbie will very think that a cert level and a LEUP is all he needs to be lega;. Big Surprise!!

- iz

RayDunak> Iz wrote:

>

excerpted from the revised minutes of the NAR Board of Trustee?s Meeting held July 31, 2003 ? August 4, 2003 (sent to Section Leaders on Thu, 6 Nov 2003)

(unapproved and are subject to ratification at the Winter Board meeting now scheduled for Feb of 2004):

an off-topic, attempt to impede a open inquiry into whats possible for rocketry and rocketers in an desperate attempt to prevent reflection on and contrasts with your ineffectiveness

I answered your transparent questions

- iz

GCGassaway wrote:

In article , Ismaeel Abdur-Rasheed wrote:

And others of note:

Motor Acceptance for Certification - Jerry Irvine asked the Board to direct Standards and Testing to accept motor submissions from ACS-Reaction labs if

Those motors were delivered by ìany legal meansî, Documents ìissued by any recognized competent authority by UNî were submitted prior to testing, and Appropriate fees were paid in advance,

The Board took no action on this request and noted that such motors would not necessarily meet current S&T standards. In particular, S&T requires documents issued solely by DOT in order to insure that motors accepted for certification could be legally shipped via common carrier means. Selected motors which could be classed DOT 1.1 can legally be shipped, under certain conditions, but would not meet either S&T or NFPA criteria for testing.

Legal Ruling Certification - A request by Jerry Irvine to issue a legal ruling regarding sections of 27 CFR 55 cannot be met, as the NAR has no legal authority or standing to issue such rulings.

DOT Legal Announcement - Jerry Irvine suggested the NAR could make note that certain motors are legal to transport based on information supplied to him by DOT. Again the Board noted that the Association has no legal authority or standing to issue such rulings, and in this particular case, the references provided did not appear to the Board to apply to such motors transported in commerce.

NFPA Code Changes - The Board directed the President to instruct Jerry Irvine to work with NAR NFPA representative Pat Miller to review requests to change various aspects of NFPA Codes 1122, 1125 and 1127 and report to the Board with recommendations.

USR Certification Apology - The Board found no cause to offer apologies to US Rockets regarding motor certifications as the motors submitted for certification did not meet DOT standards for shipment in DOT regulated commercial commerce.

Pursue FAA Regulatory Relief - In considering a request by Jerry Irvine to pursue changes to current FARís, the Board noted that the existing system of notification and waivered launches appears to work well, and that current legal resources necessary to pursue such changes were involved in other work. The Board declined to seek further regulatory changes from the FAA. Members who have FAA problems should contact the President for assistance.

====

Subject: Re: Call for Agenda Items, NAR Board Meeting Organization: Box 1242, Claremont, CA 91711 USA Date: Sat, 07 Jun 2003 15:21:31 GMT

My prior post got alot of attention, and it was in fact legally submitted for action. GFL.

So now let's try a different, more positive and more collaborative approach.

Here are several proposals for NAR board vote. Lets see how many of them get collective SUPPORT. If you support a particular proposal, simply put your NAR number under it and the thread will be mailed to NAR before the deadline.

Feel free to add a provision!

1. NAR make an official announcement that it hereby RELIES on "27 CFR

55.141(a)(8) Gasoline, fertilizers, propellant actuated devices, or propellant actuated industrial tools manufactured, imported, or distributed for their intended purposes.", and asks all members to cancel or turn in their ATF permits if the only use of such permit is for propellant. NAR members who will maintain ATF permits are asked to log-out all their propellants from any magazine.

1. NAR make an official announcement that recreational rocket motors are legal to transport under DOT regs and rulings including state to state based on, "DEPARTMENT OF TRANSPORTATION, Tony Alcocer said: I called the DOT this morning (909-937-3279) To see what they required in the way of permits or placarding. I did this in part becasue my ATF agent is gonna ask. I got ahold of Lee (ext 7224). I explained that I was in the hobby of sport rocketry and I wanted to know what they required in regards to DOT regs. He needed "UN" numbers which I was able to supply him with. I got them from Aerotech's web page. I gave him UN0351 which is for 38mm loads (class 1.4) I also gave him UN0275 which I believe is for 98mm loads (class 1.3) He looked them up to see what they were. He stated that since it was "for private use and not in commerce that the DOT did not require a permit or placarding."

2. Also, 18 USC Section 921 states

(4) The term ''destructive device'' means - (A) any explosive, incendiary, or poison gas - (i) bomb, (ii) grenade, (iii) rocket having a propellant charge of more than four ounces, (iv) missile having an explosive or incendiary charge of more than one-quarter ounce, (v) mine, or (vi) device similar to any of the devices described in the preceding clauses; (B) any type of weapon (other than a shotgun or a shotgun shell which the Secretary finds is generally recognized as particularly suitable for sporting purposes) by whatever name known which will, or which may be readily converted to, expel a projectile by the action of an explosive or other propellant, and which has any barrel with a bore of more than one-half inch in diameter; and (C) any combination of parts either designed or intended for use in converting any device into any destructive device described in subparagraph (A) or (B) and from which a destructive device may be readily assembled. The term ''destructive device'' shall not include any device which is neither designed nor redesigned for use as a weapon; any device, although originally designed for use as a weapon, which is redesigned for use as a signaling, pyrotechnic, line throwing, safety, or similar device; surplus ordnance sold, loaned, or given by the Secretary of the Army pursuant to the provisions of section 4684(2), 4685, or 4686 of title 10; or any other device which the Secretary of the Treasury finds is not likely to be used as a weapon, is an antique, or is a rifle which the owner intends to use solely for sporting, recreational or cultural purposes.

This would say that a model/LMR/HPR, which is not designed as a weapon is not a destructive device. This should also be included in NFPA

1122/1127.

1. However, 18 USC Section 841 defines Explosives as

(d) Except for the purposes of subsections (d), (e), (f), (g), (h), (i), and (j) of section 844 of this title, ''explosives'' means any chemical compound mixture, or device, the primary or common purpose of which is to function by explosion; the term includes, but is not limited to, dynamite and other high explosives, black powder, pellet powder, initiating explosives, detonators, safety fuses, squibs, detonating cord, igniter cord, and igniters. The Secretary shall publish and revise at least annually in the Federal Register a list of these and any additional explosives which he determines to be within the coverage of this chapter. For the purposes of subsections (d), (e), (f), (g), (h), and (i) of section 844 of this title, the term ''explosive'' is defined in subsection (j) of such section 844.

Since neither APCP nor rocket motors have "the primary or common purpose of which is to function by explosion" then I would be satisfied for this to be in NFPA 1122/1127.

1. Fix the offset distance tables in all places! NAR # N-s M Irvine B 2 5 2.24 5 feet C 3 10 3.16 15 feet D 4 20 4.47 15 feet E 5 40 6.32 15 feet F 6 80 8.9 30 feet G 7 160 12.6 30 feet H 8 320 17.9 30 feet I 9 640 25.3 50 feet J 10 1280 35.8 50 feet K 11 2560 51 100 feet L 12 5120 72 100 feet M 13 10240 101 100 feet N 14 20480 143 100 feet O 15 40960 202 300 feet

1. Adopt a NAR official policy of definitions:

PAD (as currently defined) and relate it as applying to SU and RL motors.

TPD and this time do it right. 125g, no thrust limit, 0.05 sec burn time limit, any hazard class it qualifies for. Using ANY CA or AHJ (UK, Canada, USA, China, NAR, IEAS). IEAS can do the high explosive testing portion BTW.

Classification: Series 1 and 2 tests and if a motor passes any test it shall NOT be subject to arbitrary rules reentering it into Class 1. If it drops from Class 1 it drops from class 1 and gets NAR's full endorsement for same with this immediate benefit:

"A specific series of tests determines the hazard classification. The manufacturer's knowledge of the material can, in some cases, substitute for some of the tests in this process. In the absence of assumptions, except a concern that the material is explosive, the material moves through Test Series 1 and 2 in that order. Test 1 looks at output ascertaining if the material exhibits explosive characteristics. If not, then for transportation classification, it exits from Class 1 consideration at this point."

1. NAR should apologize to USR for not certifying their motors despite having its OEM having Competent authority approvals, continuity of busines, ATF permits when illegally demanded by NAR and TRA, CSFM for California sales and of course local permits.

1. Make proposals to pare down NFPA-1122, 1127 very substantially and make the remaining language definitions and exemptions ONLY. Refer standards (Safety code, motor cert rules) to NAR internal policy as amended. Heck, be like NFPA and SELL those documents to fire authorities for revenue!

2. Kill 1125 and admit it was a horrible disaster.

1. Obtain a new FAA notification scheme for rockets flown under VFR and traveling to under 15,000 AGL with no propellant or mass limits. Mass-market HPR.

2. Obtain USPS aprovals for mailing the newly defined flammable solid (or 1.4 or lower) motors under 1 pound per individual segment (including in a SU or RL) and under 25kg per individual box. Get DOT to generate a CA document (applicable to any motor NAR approves) for these to travel in ANY conveyance marked brown box with no labels and perhaps some descriptive marking. Anyone can ship or reship.

1. Make all past and future motor certifications permanant.

2. Dissolve the NAR for crimes against the hobby.

1. . . .

Very well said, Iz. It is obvious to me that you are looking at possibilities and "how it should be done", and not how existing organizations currently are.

I find it a very useful conversation set that _ALL_ current and would-be rocketry organizations should participate in, and pay attention to. An open discussion with an open mindset... wow, what a concept.

~ Duane Phillips.

Except these motors totally bypassed recertification, thus the problem wasn't caught until they showed up inthe field and started failing at unusually high rates. PROPER recertification of the outsourced motors would have caught this change before people had rockets damaged by these motors, and prevented the need for questionalbe "consumer modification" of the affected motors.

This is the #1 reason why we need a legitimate test organization to certify our motors. The other is to determine the actual output of those motors. Those who were around in the early days (before 1993 or so) of HPR remember the failure rates of some of the smaller motor manufacturers, or the huge difference between motor batches, or motors that were considerably under (or over) their rated performance. Kind of hard to comply with an FAA waiver when an occasional motor mighe produce 25% more power than the manufacturer claims.

Agreed. Self testing by legitimate organizations has been and will always be a better arrangement than government regulation. The HAM radio model is ideal for us.

Bob Kaplow NAR # 18L TRA # "Impeach the TRA BoD" >>> To reply, remove the TRABoD!

UKRA don't do certs.

I was thinking along the lines of a monitored self-test facility. A manufacturer would bring motors and support equipment to the facility. Data collection would be handled by the test organization but all other activity would be by the manufacturer. No storage, transportation, regulatory checks. Only validation of the motor performance.

This would involve a facility with test stands, load cells, data collection system and safety equipment.

Any idea of how much it would cost to set this up?

This would allow shutting down the test facilities at TRA and NRA, maybe even CAR if handled properly.

It would also guarantee that motors would be tested not shelved or "lost".