NFPA 112? Questions

Actually, to me, as a contributer to the legal fund, it is extremely important.

Bob

governmental

I disagree, for reasons I posted in the part you snipped, and for reasons as follows (among others).

Also, you now erroneously equate an entity that would "build motors" with an entity like the NAR. In so doing you unavoidably infer that the trade of the motor manufacturer might be restrained, simply due to arbitrary NAR requirements placed on the "in crowd" of motor builders.

So I will use and modify your last statement, to make my statement:

If I choose to build motors and sell them without NAR certification because NAR required proof of government documents that the government does not itself require, my market will have to be something other than NAR launches. But because of the market dominating NAR organization, I would not only have to be a motor manufacturer, but I will also have to spend far more time, effort and energy to build a minute fraction of such a market for those launches, just to help people understand that a national organizational certification is not required to legally fly my motors, than I would have had to if the NAR had not required such an arbitrary condition, when I should by my compliance with all applicable _law_ have been granted certification. In my opinion, this condition would be a major component of a legal definition of trade restraint.

I will restate it another way:

The more public an entity becomes, the more the entity is controlled by the public. With the face value and recognition level that NAR currently enjoys, that is not so enjoyed by any other entity in the world (as NAR similarly states itself), I believe it could be easily proven that current NAR motor certification requirements are sufficient to establish "majority" trade influence on motor manufacturers. Is there any other consumer rocketry organization like NAR that has even half of the membership NAR enjoys? So this overwhelming majority can only use motors that are certified by NAR.

That is substantial trade influence.

All well said but a huge market not NAR members use motors certified by NAR and look for that due to decades of enculturation. As such mostly non-members of NAR refuse to buy motors unless they are NAR certified. NAR has persistently maintained NAR certification is needed to be legally compliant, even for nonmembers. I cite a LIVE source:

"Rocket Motor Information

State and federal law require all rocket engines to be independently tested before they may be sold in the United States."

Checkmate.

Jerry

"isn't really the case"?

Is that your way of not "really" saying anything? Either an LEMP is required by law or it isn't.

~ Duane Phillips.

You still haven't supplied any evidence that the law does not require these things. They are legal requirements, not "arbitrary NAR requirements".

I still haven't seen any evidence that the government does not require these things.

Right. Just as if you were selling motors that were not contest approved, you would have to find another market besides NAR contests. Or if they weren't CSFM approved, you'd have to find a market other than in CA.

At NAR launches. They can fly whatever the want at unaffiliated launches -- unless the law requires motor certs, which you claim it doesn't.

In what way? Are you suggesting that the NAR should tell manufacturers NOT to comply with the laws as they are currently enforced?

Duane wrote:

Because I want to know how committed they are. If they don't believe in the cause for which they have file suit, then perhaps we need someone else there.

Actually, Ray, there is another alternative.

DON'T ASK.

A manufacturer having or not having a LEMP (1) is none of the NAR's business, and (2) does not change the reliability of the motor (which is what NAR should be interested in).

If the BATFE, NFPA or local authorities want enforcement, they should get off their collective asses and do their f-ing jobs. It is not the responsibility of a small, non-profit, private organinzation to enforce the law.

Bob

the same "don't ask" policy should apply to TRA as well

see Tripoli Research Safety Code (April, 2002) at

Chapter 4 Limits of Liability

4.2 Disclaimer 4.2.2 The Tripoli Rocketry Association does not regulate, approve, or officially support or endorse any propellant manufacturing or fabrication process, or in any way imply such approval.

the operative words being "does not regulate ... any propellant manufacturing or fabrication process"

despite this statement being in the Research (i.e.; "EX") Safety Code, the use of the term "any" is not qualified to limit its scope to EX motor manufacturing alone

- iz

I was exploring the question of whether USR motors can be used at Tripoli EX launches, as EX motors by definition are not certified. Observe.

reference: Tripoli Research Safety Code (April, 2002) at

first, note the following:

4.2 Disclaimer 4.2.2 The Tripoli Rocketry Association does not regulate, approve, or officially support or endorse any propellant manufacturing or fabrication process, or in any way imply such approval.

the operative words being "does not regulate ... any propellant manufacturing or fabrication process"

USR motors "are not yet in the process of being certified", and so meet following requirement:

9.12 Approved Motors 9.12.2 Motors which have been manufactured by a Commercial Motor Manufacturer and which are not yet in the process of being certified and are not yet intended to be available to Tripoli members commercially, shall be deemed "experimental" and shall be flown or static fired only at Tripoli Research Launches.

9.12.2.1 Motors manufactured by a Commercial Motor Manufacturer are allowed only if they meet with all provisions of Chapter 7 of this code.

but that contains a requirement that "Commercial Motor Manufacturers" meet other conditions, indicated elsewhere:

Chapter 7 Commercial Motor Manufacturers and Tripoli Research

7.1 A person is determined to be a Commercial Motor Manufacturer if he meets the definition of a Commercial Motor Manufacturer as set forth in this code. 7.2 Commercial Motor Manufacturers at Tripoli Research Launches 7.2.1 Commercial Motor Manufacturers are welcomed at Tripoli Research Launches provided they follow all the provisions of this code.

like the (wrongful) requirement for a LEMP:

3.2 Tripoli Research Definitions 3.2.3 Commercial Motor Manufacturer. An individual, partnership or company who possesses a Low Explosive Manufacturing Permit (LEMP) and who also has Department of Transportation (DOT) UN classification and can legally transfer, ship, or sell motors to others.

yet, as USR fails to meet their (arbitrary) definition, USR is not a "Commercial Motor Manufacturer"

so, anyone can use USR motors at TRA EX launches, right?

nope, there's a "Jerry-safe" rule:

3.2.6 Experimental Motor. Any non-certified, non-commercial motor, made by individuals for their own personal, non-commercial use.

so only Jerry could use USR motors at TRA EX launches (that is, if they hadn't wrongfully expelled you)

why is a motor made by someone else not an "Experimental Motor"? Why can't you "experiment" with USR motors, esp. given that their uncertified status means that TRA/NAR has not verified its operational characteristics?

- iz

Even this is an old thread that has been beat to death (and shows precisely why I was not reinstated, which had nothing to do with FAA waivers or apologies).

It is funny the extent they went to reallycatch all possible elements to "keep me out".

So many illegal and arbitrary rules for a singular goal.

Wanna know what is truly phunnie? I insist NO customer EVER fire a motor at a NAR or TRA launch to assure that when the motors they want are not available they have the opportunuty to properly suffer. I would never have predicetd errortech would burn down!!!

And it had the side effect of rapidly ramping up garage motor builders so they could "follow the rule". Now a hundred or so people, all TRA members are making propellant in their kitchens and garages all with no prior propellant experience, or any typical precautions. One guy I know had a propellant accicent with ONE POUND of propellant and was burned on

80% of his body with 1st and 2nd degree burns. Yet another was burned severely with a couple of ounces of propellant and medivaced at ultra high cost to a burn center.

These guys are looking for trouble.

There is a REASON why commercial motors are what is called for in MR and HPR. Non-distributed risk.

Let alone any compliance issues.

While TRA is illegally asking for LEMP's of propellant manufacturers as a means to cull the ranks of suppliers, they are blatently allowing/encouraging their members to engage in vastly less safe and far more questionable activity state law wise and certainly county law wise.

And when the shit hits the fan it will be in the news as HPR club members die in home brew propellant accident.

Just Jerry

Differentiationofrocket stytles.Mandatory.

Iz wrote:

Don't forget expired certified motors are not allowed either; Vulcan, Rocketflight, Synerjet....

Sucks because of a old Vulcan H80HF and a H100SS :(

Ted Novak TRA#5512

It was also used to refuse my motors I built for a custom BALLS project where 70% of the team members were TRA members, including the rocket, casing builder and project leader, except me and an electronics guy and a trailer/truck driver (old, no fancy paint).

Jerry

But those are never enforced against.

the rules seem pretty arbitary to me

EX might be considered to have a higher risk profile due to the absence of standardized manufacturerig processes (although what I've heard from EXers is that there reliability rate is higher than commercial motors; e.g.; less CATOS)

so that justifies a variation in safe distances

but once the safety condideration is addressed, why should it make any difference what you fly? Uncertified, expired, home grown - who cares? It would seem that flying both uncertified and expired motors are a valid subject of experimentation.

- iz

Jerry Irv> >

They are intended to allow members to build and fly their own motors (individual or as a team), while at the same time making it difficult for commercial manufacturers to bypass the cert process. What's so arbitrary about that?

Based on anecdotal evidence from the braggarts of successful ones, not from a wide ranging poll or from any even rudimentary statistical study. A manufactured producton on the other hand has a built in statistical feedback loop. Known batch sizes and known returns as people whine their rocket was crashed by an errormotor.

Fragmentation risk is associated with offset distances, NOT motor reliability.

Well at least in a non-existent common sense and scientifically justified world. Where is the ONE place safe from rocket incidents where the motor does not fail at ignition? The launch pad! The closer you get to it the safer you are from non-cato events. Cato events have a small and finite "blast radius" typically 5-50 feet for A-K and maybe 50-100 feet for L-O.

Well at least in a non-existent common sense and scientifically justified world.

Nobody wants to "experiment" more than a manufacturer (on his day off) who actually ENJOYS flying rockets and probably has a few great ideas that will never be certified because they are not manufacturable.

The motors you can buy by the hunded are crap motors.

Besides. How come Gary can fly wierd motors and Jerry cannot? Huh?

And there is no rule the motor guy need be a TRA member, only the project leader.

I also noticed people were allowed to fly rockets with surplus propellant from I believe UPCo (a military contractor who has in no way submitted to the TRA process) yet members of TRA wanting to use USR propellant as a tiny subcomponent of their overall project are routinely refused.

Jerry