NFPA 112? Questions

jerry you seem to think, evidently like alot of other people here that the NAR cannot hold 2 opposing ideas in their heads at the same time...... Is it possible that the NAR as far as the lawsuit is concerned doesn't think APCP rocket motors are not explosive? (even though in the NFPA codes they also do specifiy that rocket motors have to be class 1.3 or 1.4 explosives prior to certification by the NAR/TRA) while at the same time requiring manufacturers of such APCP rocket motors to follow federal law and get a LEMP? Or maybe you do have a point and they are just talking out both sides of their mouths? playing both sides against the middle? Or maybe they just do not want to do business with you would your past indiscretions? You can whine and cry all you want in here and nothing will change....IF you are really serious about getting your motors certified, and you are doing everything they want of you and they still will not cert them , SUE them..... otherwise all else is a waste of bandwidth .................. shockie B)

No, I would not be manufacturing the components.

Perhaps you meant that I would have to have a LEUP since I would be using the components (although I don't know any of the standard components that require an LEUP).

Bob

Which components would those be? The ingredients are typically just combustibles or oxidizers until combined into a propellant.

-dave w

False and VERIFIED by ATF agents. Your false representation is trade libel to the extent it is relied on for anything at all.

Jerry

Be careful what examples you give. If you don't know the whole story, you may be barking up the wrong tree. Remember, the BATFE used the example of the Challenger. Remember that grain elevators have been known to explode. Should we all need a LEUP for flour?

The PEPCO explosion was from a dust cloud of micro-ground AP and had nothing to do with APCP.

Bob

Not true of course and I posted the original documents for YEARS right here to offset the false claims. Furthermore when asked to show the alleged dcument it was in fact a FAX FROM AEROTECH. Gee I wonder how that happened?

At no time was this ever even claimed to be a document SUBMITTED TO TRA BY ME BY ANY PRINCIPAL.

However maybe now that has changed too?

Two thoughts?

You seem to be the one.

DOT (49 CFR) classifies a transportation hazard (ie 1.3, 1.4, 4.1). For example it calls things 1.3 and 1.4 that CANNOT EXPLODE.

ATF (27 CFR) is a different agency. Different regulation book. Different everything. They have a list of explosives. Some forms of AP are on it (45µ is NOT on the list and by reference/logic/law neither is a DESENSITIZED APCP made from it (rubberized). You will not find this simple fact/claim in the NAR/TRA lawsuit.

FURTHERMORE PADS are exempt from ATF regulation per 27 CFR555.141-a-8 and the definitionof a PADis:

"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."

NAR and TRA are insignificant hairs on a festered pimple on the butt of ATF and DOT. And maybe you are so confused by their institutionalized obfuscations and lies but the fact they do them is the problem.

Which itself is EXEMPT!

Did you read this before you sent this?

Joel. phx

regulations.

I for one hope not considering just how wrong it is.

Let me summarize this wacky (shocky) post.

Take 3 ingredients, each not ATF regulated (AP,AL,HTPB), mix them up and make an unregulated finished product. But for a time it is regulated while it is being mixed? What is the point of exempting something if it is not exempt?

Jerry is your legal god.

It was explained to me "typed name crossed out and handwritten name just above the crossout". How hard would it have been to request DOT issuance of corrected paperwork? It's been 5 years.

There was another case where one of the requested documents wasn't required by locality. As Phil wrote, some type of verifcation of address is necessary.

1127 talks about how motors must be stored. I'm assuming 1125 does the same for manufacturers. How would one verify that the facility is complying with the NFPAs? Certainly you could fly a boardmember out to observe the facility. To obtain an LEMP, a government agent must inspect the magazine, thus ensuring the NFPAs are being met.

Besides, one of the personalities said he had/s a LEMP so this approach is pointless.

It's been 5 years. It only took Aerotech 2 years to rebuild from the ground, how long could getting the paperwork in the right name take? Start digging through old threads. He has no interest in certifying motors.

Joel. phx

manufacturers

POINT. If you dig through the old threads, you'll see the same arguments time and time, and time, and time, and time,,, you get the point. It's been

5 years, he has NO interest in certifying any motors.

Joel. phx

Worse than the glue threads.

I'm not interested in Jerry certifying his motors. That's his problem (and/or his customers problem). I'm more concerned with aspects of the rocketry organizations that may be extending beyond their boundaries.

For example, in the example earlier in the thread, I discussed how my particular city doesn't have business licenses, so requiring such by TRA would be impossible to achieve.

For the above item, I come back to the question of how/why it is the concern of the NAR or TRA whether the manufacturer is complying with the NFPAs. I'm unaware of either NAR or TRA having law enforcement capability, and I resent the implication that they can do what is effectively law enforcement work, especially when the hobby ALREADY has too much involvement from the BATFE, etc. Is it up to the certifying organizations to check and see if my tap water meets the local drinking water standards? Does NAR or TRA validate (using Aerotech as an unfortunate example) that the manufacturer is complying with OSHA requirements? No, because they are not government organizations, and do not have powers of enforcement.

I'm not doing the above for or on behalf of Jerry, I'm questioning it because SOME of what I've seen stinks to high heaven. Perhaps these things are honest mistakes, perhaps they ought to be re-evaluated in light of the lawsuit, perhaps things should be made easier because the hobby has matured, perhaps roadblocks to manufacturing need to be removed to help grow the hobby.

I'm simply opening up the discussion to get some educated/experienced responses, and perhaps to throw a little common sense in here.

David Erbas-White

P.S. I'd like to add that the questions I had over the past couple of days, for example, about the NAR renewal form have been addressed to my satisfaction for the moment, and that I commend the NAR Board Members that I've communicated with for their openness and responsiveness. This is simply another 'question' along those same lines.

Or Tripoli really is that compulsively horiffic.

Unless no LEMPis required (as TRA has since verified and proffered in a lawsuit).

Jerry

I trust that was answered? If TRA is backed by insurance, would the insurance company want to get back to the manufacturer if there's an incident? That's a local 'governmental' issue, yet important to the TRA. Yes?

Ok, so let's take a step back. The certifying organization only looks at the performance of motors. Is that in the best interest of the club? Say Bob has a business license for selling widgets. Under that same license, he submits kitchensink motors for certification. Certification passes on the 3 motors, delays, pressure, thrust all OK. Bob sells 10,000 casings and

50,000 grains none of which are within spec. Board says 'hey, we did our job'. State says 'we haven't adopted 1125 so no state requriement to test batches'. State fines or shuts down "Bob the basement bomber" {as the paper reads} so no more grains produced. Everybody happy?

Well, as they say, why not go to the horse's mouth instead of here, it's backend. Fire the TMT off a note,...

Joel. phx

What was the answer?

Ok, what was the question,...

>

David E-W. wrote:

I guess ads in HPR Magazine don't count then...

"Legitimate" business? Legitimate compared to what? Why should one have to meet some "minimum" threshold of "establisahed-ness" to be considered "legitimate".

Looks like the criterion was intended to grandfather in "established commercial manufacturers" while placing obstacles in the way of garage-level startups who are not at the level of having "catalogs" or "advertisments" etc.- even though that's where "established" suppliers come from.

With any other product, the hobby celebrates the existence of "cottage industry" vendors, like the rail button guy or your parallel staging hardware. But when it comes to motors, we seem to still be tainted with the primeval Model Rocket Religion - "people don't make motors; motors come from corporations..."

-dave w

E-matches...

Which is why I think that the only way this whole thing will come to a head is someone being charged with the crime of not having a LEUP while in possession/using APCP. This whole thing would be decided in court during a trial, setting precedence.

-- Drake "Doc" Damerau

NEPRA President NAR Section 614 NAR 79986 L3 Remove "My Shorts" to reply