[F-FT] Comments on motor decertification requested

During the final months of the A10-0T certification, I burned up dozens of them. At least 7% failed (blow through). They were from "pink blister packs".

That's all - no other comment.

I am pretty sure it is simple momentum of an arbitrary three year rule.

Some felt if it ain't broke, don't fix it.

Others felt it was always broke, fix it now.

Bundick has been an advocate of status quo on the basis that one motor over three decades ago was the "poster child" for a motor that goes bad.

However as an advocate of non-decert, I have stated that any motor SHOWN to go bad can be separately decertified. But even in that case all it does is make a motor that was obtained legally by a general consumer and more likely than not in a motor collection (since flying it would be stupid) a "destructive device" or whatever harsh thing it might be declared as.

Even motor FAILURES are protected against by the safety code itself so there is no rational or scientific arguement for decert.

The entire arguement is tradition, regulation as exists, and politics.

Ending decert would instantly legalize all motor collections.

Ending decert would make available the option to reallow contest cert if availability were to change.

Ending decert would mean far easier renewal procedures could be empoloyed for oddball motors.

Jerry

I agree.

david: Unless NAR S&T has changed there policies, heres what was effect in 1993.. I have emailed NAR S&T at least twice over the past couple years asking for the latest version of this document (assuming there is a more recent version in effect) and have never received a reply... perhaps you should email them and ask?

NAR S&T CERTIFICATION POLICY FOR MODEL AND HIGH-POWER NON-PROFESSIONAL ROCKET MOTORS

Types of Certification

-------------------- A motor is certified by the NAR Standards and Testing (S&T) committee as a model rocket motor or as a high power rocket motor. The type of certification granted a motor (model or high power) is dependent upon the current standards of the National Association of Rocketry taking into consideration various federal regulations. Note that consumer use of all motors may be further regulated by federal, state, and local laws.

A rocket motor may also be granted certification for use in NAR sanctioned contests. This is known as contest certification. The requirements for contest certification are that a motor be a model rocket motor and that it be generally available.

Grant of Certification

-------------------- Certification of a rocket motor is granted after the manufacturer has supplied all the required documentation, fees, and sample motors and these motors have passed NAR certification testing procedures. Motors may only be submitted for certification by the manufacturer unless permission is granted by the manufacturer for submission from other sources. Certification is effective the day the manufacturer has supplied all materials or the day after the motor passes S&T testing, whichever is later.

Contest certification is granted 90 days after this date, but may be delayed if S&T does not find the motors generally available by then.

NAR S&T recertifies all currently certified motors triennially. Motor manufacturers are expected to submit test samples when notified of recertification testing. If a motor received its initial certification less than three years ago, it need not be resubmitted for triennial testing.

Motors must also be resubmitted for recertification if the manufacturer makes changes to the manufacturing process including, but not limited to, propellant formulation or configuration, delay formulation, nozzle design or material, casing material, or changes to the total impulse, average thrust, thrust curve, or delay time. The NAR S&T committee chairman will consult, when requested, to determine whether recertification is required.

Removal of Certification

---------------------- The process of decertification of a motor is based on the date of a significant event. Significant events include (but are not limited to):

• The day the manufacturer ceases operations.

• The day the manufacturer informs S&T (or it becomes generally known) the manufacture of a motor has ceased.

• The day the manufacturer fails to submit the motor when requested for triennial recertification.

Once the significant event has occurred, decertification begins. During the decertification period, motors manufactured after the date of the significant event are not certified. Motors manufactured before the date of the significant event remain certified according to the following timetable:

• Contest certification for that motor is dropped at the end of that contest year. A contest year runs from July 1 through June 30 and includes the NARAM at the end of that contest year, which may be after June 30.

• General certification as a model or high power rocket motor is dropped three years from the date of the significant event.

The only exceptions to the above decertification schedule is as follows:

• In the case of government regulatory action, decertification may be immediate.

• In the case of consumer complaints, safety problems, blind testing failures, or triennial testing failures, NAR certification may be suspended or withdrawn if the manufacturer fails to solve the problem within six months from the date of notification.

It is against the NAR Safety Code to use decertified motors. Use of decertified motors is not covered by NAR insurance and may also be a violation of state and local laws, where applicable.

Once decertification procedures have started, a motor can only be recertified by treating the motor as if it had never been previously certified. The manufacturer must submit the documentation, fees, and motor samples that normally accompany the initial certification of a new motor.

and did everybody notice this:

"It is against the NAR Safety Code to use decertified motors. Use of decertified motors is not covered by NAR insurance and may also be a violation of state and local laws, where applicable."

It doesn't say test.

IF notified.

Different term testing used here.

I propose it be changed.

So even major changes do not necessarily require testing. Aerotech is good to go on casing upgrades on Econojets.

Propose to omit all the above.

Why? Are you aware of anything specifically that was already requested or being discussed? I don't want to waste my time if this kind of stuff is already under consideration.

David Erbas-White

I don't know if it has to do with old motor certs, But I bet that after the NAR board meeting that was held in March, we hear some new news about motors certs.

---snippage of great stuff-----

My spin:

"Motors used at sponsored launches are required to be certified. Certification ensures the motor will preform at its advertised levels whether used for sport or competition. The list of certified motors is maintained at

"Motors shall not be used for any launch whatsoever should the manufacturer issue a recall. Comply with the manufacturer's recall instructions to return or properly dispose of recalled motors. Motor certification shall be suspended automatically whenever reports of unsatisfactory performance (MESS reports) are received indicating a failure rate equal to or exceeding 5% in any one month period. The manufacturer shall be permitted a 90 day window beginning on the day of suspension of the certification to investigate and correct the deficiency. If at the end of the 90 day period the manufacturer has neither corrected the problem nor recalled the motor it shall be decertified and prohibited from further use."

John

Here's the problem with what you've written - the major reason most folks join NAR is because of the insurance coverage. As you've written it, one could ONLY use such motors at a 'sanctioned' launch, which typically would mean one that is held by a section. You completely negate the user who may have met all of the requirements to launch BY THEMSELVES, but relying on the NAR insurance.

There are TWO aspects to the decertified motor problem. Problem one is that of flying at 'sanctioned' launches (ones held by a section). If one of the NAR sections holds a launch out in the desert, it is still 'illegal' to use such a motor. The second aspect is the insurance aspect. Even for a 'lone ranger', the NAR insurance provides (at least the veneer of) some protection (particularly when talking with non-knowledgeable law-enforcement types). However, the moment you use a decertified motor, you've lost any possibility of insurance coverage.

That's why I'm trying to word this to prevent decertification of the motors in the first place...

BTW, we're going to have the same problem with the C11-0 motors, if they keep production shut off for too long...

David Erbas-White

maybe some/all of this could/would be solved, if the motors had : Use before xx/xxxx or : DO NOT USE after xx/xxxx dates on them? Sorta like freshness labels? I might add this is already allowed per NFPA 1125.....

shockie B)

Like I said I don't think it was related to extending sport certs like you wish to do, but some kind of news should be forthcomming I hope, I hope.

Once again, black powder motors do not 'expire'. They go bad if they are temperature cycled. I can cycle a new motor in a couple of days and make it bad, or I could carefully store them for three decades and they'd still be good.

David Erbas-White

Hey Jerry why don't you get NAR to certify your motors? They know that time you shipped unlabeled motors to S&T wasn't your fault. The guys kid probably lost the stickers when he opened the box.

-----snip-----

Actually, I was carefully staying away from the insurance aspects of launching flaming pryotechnic devices into the sky :-) When I fly (most every weekend recently) I am by myself (rocketry isn't a big sport here in Camden County GA). Not being a member of NAR there is no way their insurance carrier would entertain a claim on my behalf if something bad occurred. I have my own private insurance coverage which includes a rider specifying my coverage when launching model rockets.

The verbiage can certainly be wordsmithed as required. My central point was when I show up at an NAR sanctioned launch and fly as a guest, any motor I want to use *must* be on the certification list.

What I do in my own time is up to me. Currently I'm tinkering with a titanium framed suger-fueled LEO capable 'Kitty Disposal Device' to send some company up to Laika (assuming that capsule hasn't deorbited yet).

John

Suppose a line of previously certified motors had to be decertified, either because newer versions didn't perform as required or because the manufacturer failed to meet changes in the cert requirements. If the manufacturer was dishonest, he could continue cranking out new, backdated motors indefinitely. As it stands now, unless the manufacturer was dumb enough to let someone see him backdate the motors, he could only do so for up to three years past the expiration date.

I don't know if that's _the_ reason for it, but it's one possible reason that comes to mind. I'm not entirely convinced myself that it's even a big enough issue to outweigh the benefits of eliminating the expiration dates.

manufacturer

Sounds ok to me.

What would be the realistic harm if this were to occur? I'm not advocating this, I'm asking an honest question. If the motors were found to be unsafe, they could be decertified immediately. If the manufacturer was found to be doing this, he could be prosecuted for fraud. If (as is apparently the case with Kosdon motors -- I'm going from hearsay) the organization didn't REQUIRE any date coding on the motors, that's an oversight they have to correct -- and would have to grandfather in for some reasonable time, as well.

I get real tired of having to do things in life based on what the 'bad guys might to' if they had a mind to. 'Reasonable' precautions are okay, but I just don't see the harm in the outlined scenarios.

Ditto -- I believe it might be an issue, but I think that the benefits of ALLOWING older motors to be used outweigh the possible downside. Eliminating this requirement would (IMHO) actually boost the hobby -- here's why (and this is real-life). I've heard recently that the C11-0 will no longer be made -- so, I bought a couple of extra packs.

Now, if I felt that I'd be able to use them at NAR launches over the coming years, I might have bought a BUNCH of packs, because I'd be assured that I could use them, or they could prove to be good as 'trading goods' that others would be able to use. My buying them and stashing them in my 'collection' no opens up pegs on the retailers shelf

-- which he'll hopefully fill with more motors, and so on down the line.

David Erbas-White

If the certs never expired there could not be a fraudulent claim of backdating.

The ONLY thing that could be an issue was actual product performance and under one suggestion I read here there would be a mandated 90 day compliance period.

Under those terms there would have been unlimited USR motors available after the AT fire.

Jerry

Very good point.

Oh, this is rich...

The intent of dating motors (or anything else) is to allow for finding a 'lot' of motors if they are found to be defective.

Whether or not you actually backdated motors (and I obviously don't know and have no knowledge of it), that entire incident will have colored the industry as to whether or not the certification issues can be modified. It would be easy to point back to 40 years of spotless history and say "There's never been any problem, let's consider some modifications to make it easier", but with the (unfounded or not) accusations against you, and the fact that Frank didn't date the motors at all, there is REALISTIC concern about folks taking liberties with 'the system'.

David Erbas-White

All the more reason why falsified claims by TRA (and there have been so many WRT so many people) have caused any industry damage.

I do not see people claiming errortech's foamy/recored J350 issue "damaged the industry" and it was far more widespread, recent, public, and witnesses as to truth.

Batch tracking is a manufacturer concern ONLY because if a "lot" is recalled (none ever were) and it is unclear what lot to recall it is a manufacturer risk that "all" motors might be recalled to catch the "bad lot".

In point of fact all legit USR motors (those not stolen and resold by Teeling for example, in a similar timeframe), were dated. Accurately.

I was seeking to (early) RENEW motors at the time the motors were decertified (I was never even informed of a backdating claim).

If the renewals were processed with the samples already tendered and ACCEPTED by Tripoli, this would have been a non-issue.

Between Teeling reselling stolen motors, Tripoli "losing" many samples they ACCEPTED, and the claims I never had FAA waivers (proven false), and the motor decert with NO NOTICE. I think it is clear there was something major going on and I for one had NO INCENTIVE to screw myself.

Teeling's partner in Powertech was on the TRA BOD and personally made the decision to remove me for FAA claims and was party to the decision to decertify USR and was also present and leader of the charge to certify Kosdon motors (yet another Powetech partner) in direct opposition to the partnership agreement (USR exclusive seller).

I got screwed and everyone familiar with the facts knows it.

Fine.

All l ask for now is a level playing field and it is NOT forthcoming.

Jerry