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Newbie Question : Motor Availability



This should be in the FAQ.
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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Jerry Irvine wrote:

Why?
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Jerry wrote: << That is because it describes the CHARACTERISTICS of exempt items. That is BETTER than listing them one by one. Here: "...system which is actuated by a propellant or which releases and directs work through a propellant charge">>
That describes a PAD or PAIT.
<<Does a RL motor do that?>>
Yes, but a _reload_ for that motor might be considered a different matter. Please prove me wrong!
<<Does a SU motor do that?>>
Of course.
<<Does an igniter do that?>>
Nope. It's only an initiator. An igniter can be used to light explosives, fireworks, PADs or other items. It's not a Propellent Actuated Device, and it's intended use is not PAD-specific.
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Jerry Irvine wrote:
> snipped-for-privacy@aol.com (RayDunakin) wrote: > > >>I wrote: >> >>>>Jerry, I'm not disagreeing with you, but can you >>>>please show me specifically where the regs state >>>>that propellent loads and/or igniters are exempt? >> >>> >>Jerry replied: >> >><< I did. Your ignorance of legal language and how it is APPLIED is NOT my >>fault. >> >> >>I have seen nothing in the regs you've quoted which could even remotely be >>interpreted as saying that propellent loads or igniters are exempt -- and >>believe me, I _want_ them to be exempt. >> >><< From 27 CFR 55.11, "Propellant Actuated Device. Any tool or special >>mechanized device or gas generator system which is actuated by a propellant >>or >>which releases and directs work through a propellant charge." >> >> >>Once again you have quoted the PAD definition, but it makes no mention of >>individual components, reloads, or igniters. > > > Or air bags, or SU motors.
Air bags are NOT exempted as propellant actuated devices. They fall into the "special explosive device" category in 27 CFR 555.32. This was in one of the BATFE Explosives newsletters.
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I stand corrected.
Imagine if I didn't post that what trhreads would propogate :)
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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Jerry wrote: << A PAD is: 27 CFR 555.11, "Propellant Actuated Device. Any tool or special mechanized device or gas generator system which is actuated by a propellant or which releases and directs work through a propellant charge." Note the code reference. It is a REGULATION. >>
Duh. Show me where it specifically exempts reloads/cartridges and/or igniters. It talks about Propellent Actuated Devices, but igniters are not PADs. Reloads are part of the PAD "system" and could be considered exempt that way, but unless there is more precise language exempting them, you can bet your bottom dollar that the ATF will "interpret" that gray area to suit their agenda.
It would be really helpful if we could find: 1. Some other examples of PADs which have separate reloads that are exempt. 2. A manufacturer of such, who could give us some insight without having a vested interest in the issue of rocket motors as PADs.
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snipped-for-privacy@aol.com (RayDunakin) wrote:

"Any tool or special mechanized device or gas generator system which is actuated by a propellant"
"ANY"
Mindless drivel snipped.
Jerry
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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Jerry Irvine wrote:

So are you claiming that an igniter is a PAD because it is "actuated by a propellant"?
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What are you claiming on the topic?
Be careful not to talk yourself into a corner as you do so well.
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
Opinion, the whole thing. <mail to: snipped-for-privacy@gte.net>
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GraveDavis wrote:

Jerry dodged: <<What are you claiming on the topic? >>
Answer the question, Jerry.
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I wrote:

Jerry replied: <<"Any tool or special mechanized device or gas generator system which is actuated by a propellant" "ANY" >>
Once again, you have merely quoted the definition of a PAD. You have NOT shown anything which states that individual PAD components, propellent loads, or igniters are exempt.
The definition you keep quoting does not address the issue of propellent loads for PADs. Nor does it address igniters, which are not even specifically intended for use in PADs.
There may be some precedent for exempting these things (in fact, I'm counting on it). However, unless there is some specific language that makes it clear that propellent loads for PADs, and/or igniters, are exempt, then it is a gray area which the ATF will try to interpret to suit their agenda.
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I wrote: << Once again, you have merely quoted the definition of a PAD. You have NOT shown anything which states that individual PAD components, propellent loads, or igniters are exempt. >>
Jerry dodged: << Any means ANY. >>
Yes, any PAD. But an ignitor is definitely not a Propellent Actuated Device. Reloads or cartridges are not complete propellent actuated devices, they are merely the propellent load that goes into those devices.
Now, you and I both know that cartridges are exempt despite the fact that they are not PADs, so it's logical to assume that reload kits are also exempt. But so far, I haven't seen the regs which make either cartridges OR reloads exempt. Until I do, I'm forced to conclude that these materials are in a regulatory gray area.
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snipped-for-privacy@aol.com (RayDunakin) wrote:

Nope.
You snipped the FACT in favor of an off-topic rant, but here is the fact again.
"Any tool or special mechanized device or gas generator system which is actuated by a propellant..."

False.
PADS
55.141 exemptions (a) (8) Gasoline, fertilizers, propellant actuated devices, or propellant actuated industrial tools manufactured, imported, or distributed for their intended purposes.
Nobody can force you to comprehend english. Especially not me.

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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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<< Once again, you have merely quoted the definition of a PAD. You have NOT shown anything which states that individual PAD components, propellent loads, or igniters are exempt. >>

Jerry snipped and responded: <<Nope. You snipped the FACT in favor of an off-topic rant, but here is the fact again. "Any tool or special mechanized device or gas generator system which is actuated by a propellant...">>
And still you insist on repeating the same quote over and over, without addressing the real issue. An igniter is NOT a "tool". It is NOT a "special mechanized device". It is NOT a "gas generator system". So HOW can you say that igniters are PADs?
I wrote:

Jerry gave the following one-word pseudo reply: <<PADS >>
So you're saying that reload kits and cartridges are "propellent actuated devices"? What's a nailgun then, if the cartridge is a PAD? How is a cartridge a "device"? Or a "tool"? Looks to me like a cartridge is just a tube full of propellent, that goes INTO a Propellent Actuated Device. Same with reloads.
Quit getting huffy and just discuss this logically, please. It's not like I'm trying to prove reloads and cartridges aren't exempt. Obviously cartridges ARE exempt, because I can go into Home Depot and buy hundreds of them without a permit. Logically, the same should be true of reload kits. I just want to know specifically what regulations exempt them, and how.
As I see it, you have three ways to respond correctly:
1. Show me HOW igniters, cartridges and reloads are legally considered PADs, despite the fact that they are neither devices nor tools.
2. Show me the regs that exempt igniters, cartridges and reloads as _components_ of PADs.
3. Admit that although they are clearly exempt, you don't know what regulations exempt them.
If there's some fourth answer I'm unaware of, spell it out. Don't just give some one-word answer that doesn't explain anything.
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snipped-for-privacy@aol.com (RayDunakin) wrote:

IT --IS-- THE REAL ISSUE.
DEAL WITH IT.

Yes it is. That tool starts a rocket motor.

It is CERTAINLY a gas generator system as well.

How can you deny the obvious, that you are a moron.
tool (P)Pronunciation Key(tl) n.
Something used in the performance of an operation; an instrument: Modern democracies have the fiscal and monetary tools... to end chronic slumps and galloping inflations (Paul A. Samuelson). 5.
Synonyms: tool, instrument, implement, utensil, appliance These nouns refer to devices used in the performance of work. Tool applies broadly to a device that facilitates work;
3. Hence, any instrument of use or service.
4. A weapon. [Obs.]
n 1: an implement used in the practice of a vocation 2: the means whereby something is accomplished
moron (P)Pronunciation Key(mrn, mr-) n.
moronic (m-rnk, m-) adj. moronically adv. moronism or moronity (m-rn-t, m-) n.
1. A stupid person; a dolt. 2. Psychology. A person of mild mental retardation
\Mo"ron\, n. (Pedagogy) A person whose intellectual development proceeds normally up to about the eighth year of age and is then arrested so that there is little or no further development.
n : a person of subnormal intelligence [syn: idiot, imbecile, cretin, changeling, half-wit, retard]

moron tool moron
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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What's all the fuss about, guys? The igniter is a system component of a specialized gas generator system: it's a functional _component_ of the exempt device.
-dave w
Jerry Irvine wrote:

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Dave W. wrote: << What's all the fuss about, guys? The igniter is a system component of a specialized gas generator system: it's a functional _component_ of the exempt device. >>
I agree that one could look at it that way, but it's still not cut and dried. Most igniters aren't designed or intended specifically for gas generator systems or other PADs. You'd have a stronger point if you limited it to igniters made specifically for a specific PAD system, but that wouldn't include things like Daveyfires or Oxrals, which are generic igniters used for many non-exempt purposes.
Then there's the fact that Congress specifically listed igniters as a regulated explosive, when they created the law regulating explosives. Why would they do that if they were going to turn right around and say that all igniters are exempt?
With reloads (and cartridges), the "system component" argument is much stronger. In fact, I believe that is exactly how they are exempt. After all, what good is a PAD exemption if it only exempts the tool and not the propellent loads needed to use it? Reloads/cartridges are designed and constructed for one specific purpose, and that is to be used in a specific PAD system.
Jerry keeps saying that reloads and cartridges are PADs _themselves_, when clearly they are only components. Semantics, maybe, but you can bet that the ATF will argue the semantics of it in court. They did that already when they claimed that rocket motors are not "devices". So I believe we must be prepared to argue our case with precise language and precise cites to back it up.
I don't understand why Jerry thinks that is too much to ask for.
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snipped-for-privacy@aol.com (RayDunakin) wrote:

If you simply say that about EVERYTHING, then you will never be swayed by any reading, fact, law or judges ruling.
You should go live with Mark Bundick.
He chit chats about mass limits, the "vagaries" of exemptions and such too and he is in a position of authority.
Jerry

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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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Actually DaveyFire's and Oxral's are classed inclusively with Pro38 and 54's etc. as UN0357 articles pyrotechnic NOS (completed reload device). They are no longer UN0454 igniters when configured that way.
Anthony J. Cesaroni President/CEO Cesaroni Technology/Cesaroni Aerospace http://www.cesaronitech.com / (905) 887-2370 x222 Toronto (410) 571-8292 Annapolis

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This is an "article approval". This refers to DOT/UN. A sepatate issue is ATF. All those items mentioned are ATF exwempt. Always were.
Jerry
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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