Engine experts riddle me this

Prior to the rewrite for 1125, did 1122 say that ?

my tiny mind is telling me no it did not.

Reply to
AlMax
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Any "change" requires recert. Unifying nozzles between two motors clearly indicates at least one motor changed.

One would think all "new case" AT motors need to be recerted too.

The AT by Ellis most certainly should have been recerted but that were not and that was a BUNCH of MAJOR changes.

Let's face it.

Tripoli militantly applies rules AGAINST USR and KE and in favor of Ellis, Aerotech and RCS.

It's true.

You may even like the result (USR/KE haters) but the end does not justify the means ACCORDING TO THE RULES.

Jerry

Reply to
Jerry Irvine

The question was relating to decertified Estes/Centuri "shorty" motors.

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

Reply to
Bob Kaplow

Who says they haven't been?

Ellis, AT and RCS all have valid LEMPs and DOT approvals. So do the other legal manufacturers. You don't.

Reply to
raydunakin

Let's see... we insist (in the name of engorcing "consumer and not amateur" rocketry, that propellant must be "manufactured by companies", not just "made by people" - i.e., a "commercial product" of a "licensed Manufacturer of Explosives"... is it any wonder that BATF's management gets the impression that the regulations applicable to "Commerce In Explosives" ought to be applicable?

-dave w

Reply to
David Weinshenker

So you agree with me and refuse to say so?

Reply to
Jerry Irvine

It is no wonder. Ray says so and TRA TMT and TRA BOD goes along with it :)

Reply to
Jerry Irvine

companies",

"licensed

Amateur rocketry is making motors for your own use, not selling them. Manufacturing motors (or anything else) for sale is commercial manufacturing.

ATF itself says that if you're making explosives for your own, non-business use, you don't need an LEMP. If you're selling the stuff, you're engaging in commerce.

BTW, the ATF seems to prefer the term "distribution of explosives", and defines "distribute" to mean "sell, issue, give, transfer or otherwise dispose of" -- 55-841(n)

Reply to
raydunakin

No, I'm asking a question. That's what the little curly thing with a dot under it means, at the end of the sentence. ;)

>
Reply to
raydunakin

It's interesting you should feel you are in a position to say that.

  1. What is the ANSWER to my question?

  1. What is the answer to Dave W's question to you?

Let's see you ANSWER something for a change.

Reply to
Jerry Irvine

Explosives, yes. EXEMPT materials, no.

It really IS that simple.

Jerry

So every "TRA-EX" sharing of a motor is non-compliant then!

Jerry

Reply to
Jerry Irvine

Wrong. Smokeless powder is exempt, yet manufacturers of smokeless powder are required to have an ATF permit. Black powder also has an exemption, and again the manufacturer is required to have an ATF permit. The Orange Book makes this VERY clear. And those exemptions are listed in the same section as the PAD exemption.

otherwise

What you call "sharing" a motor doesn't involve selling, issuing giving or transfer. The motor maker is simply using the motor he made, in a rocket supplied by a partner.

Reply to
raydunakin

Poor Jerry. He's 'SPECIAL' and can't follow the same rules as everyone else.

Reply to
Phil Stein

huh?

Reply to
Jerry Irvine

,

explosives",

Should I have used shorter words? Do you need a link to a dictionary?


Reply to
raydunakin

What Ray means is that if you call it an "amateur team project" instead of "Commercial Distribution", it is perfectly legitimate for someone to bring his motors to the field and have them fly in rockets that someone else built.

-dave w

Reply to
David Weinshenker

instead

someone

It has nothing to do with what you "call it". It's all about whether or not a transfer takes place. If I build a motor and my partner builds a rocket for me to fly it in, the motor isn't changing hands. It isn't being sold, given, issued or transferred to another person.


Reply to
raydunakin

Oooooh! Now I get it. I was confused by the actual LAW and REGS. Sorry!

Reply to
Jerry Irvine

"defines "distribute" to mean "sell, issue, give, transfer or otherwise dispose of" -- 55-8 41(n)"

Looks to me as if CFR defines it, not Dunakin or TRA. So if motors are "born regulated" they also are subject to this rule.

The above language clearly would ban ANY transfer or discharge by/to anyone other than the lisencee. I can read.

So if motors lose their 27 CFR 555.141-a-8 exemption (either by reg change OR by voluntarilly TRA style exposing them to the permit system), no loans, borrows, shares, watch while you launch it, can happen. Ever.

It would be a FELONY.

Hmmm. Maybe TRA is felonizing its members as we speak. Seriously.

Jerry

Reply to
Jerry Irvine

Randy

Estes motors are certified by NAR S&T, a recognized testing organization acceptable to the authority having jurisdictionas per NFPA

1125-8.1.4, to meet the advertized manufacturer's specification on total impulse, average thrust and ejection delay times as per NFPA 1125-7.8

Different lots of black powder can have different burn rate characteristics. Because of this Estes continously performs static fire lot testing of their motors in accordance with NFPA 1125-7.8.1 to insure that the total imulse of the motor is within 20% of the certifiction value, the delays are within 20% of the certification values. If the test motor is outside the allowable variations, the lot must either be destroyed, or corrected and retested according to NFPA

1125-7.8.6

If the lot is corrected, it must be retested, and can be sold if it meets performance specifications obtained at the time of certification. Adjusting nozzle throat dimension is a perfectly acceptable and allowable manufacturing method to bring a motor lot into compliance and does not represent a redesign of the motor so recertification is not required.

In fact, a manufacturer is allowed to make a physical redesign and/or chemical composition change for a certified motor provided that the changes do not alter the specified performance levels of the motor by more than the allowable variations specified in NFPA 1125 simply with a written notification to S&T prior to sales as per NFPA 1125-8.1.6

If S&T has either safety or performance concerns about the modifications, it can and does request further information from the manufacturer to validate the design or performance claims, and can upon further review, decertify the motor and require a recertification if safety or performance questions are not be answered satisfactorily under NFPA 1125-8.4.

Bob Krech NAR 78096 Member CMASS and NAR S&T

Reply to
Bob Krech

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