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
The question was relating to decertified Estes/Centuri "shorty" motors.
Bob Kaplow NAR # 18L TRA # "Impeach the TRA BoD"
>>> To reply, remove the TRABoD!
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
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)
It's interesting you should feel you are in a position to say that.
1. What is the ANSWER to my question?
2. What is the answer to Dave W's question to you?
Let's see you ANSWER something for a change.
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.
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
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.
"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
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
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