[Planet News] NAR/TRA Joint Statement on BATFE Issues, dated October 9, 2006

Planet News · 2006-10-10T01:29:51+00:00

This message will report on the BATFE?s Notice of Proposed Rule Making (NPRM) on the definition of propellant actuated devices (PADS)and our October 17 hearing in US District Court.Notice of Proposed RulemakingOn August 11, the Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE) published in the Federal Register a proposed rule to state that hobby rocket motors are not propellant actuated devices (PADS). If accepted as a final rule after public notice and comment, HPR rocket motors would be subject to all applicable licensing and controls under Federal explosives law, the legally promulgated regulations, and ATF policy rulings.You can download the full text of the proposed rule, including information telling you where to file your comments at IS CRITICALLY IMPORTANT, BOTH FOR THIS PROPOSED RULE, AND FOR OUR ONGOING LITIGATION EFFORT THAT ALL MEMBERS COMMENT OPPOSING THIS NPRM.We have reviewed the NPRM with counsel and offer the following suggestions for making responses:1. Airbag manufacturers have been treated differently re: a PADS determination. In their June 1997, the ATF states that airbag manufacturers must have an explosive manufacturing license, yet state in the NPRM that airbags are PADS.2. There are no clear technical standards for previous PADS classifications listed in the NPRM. 3. Congress did not specify that mechanism, metal work or inclusion in, exclusion from or stand alone was a requirement for PADS.4. ATF has not established a clear process for application, review, adjudication and appeal for parties seeking a PADS definition for their devices.5. Rocket motors, as used in practice, have parallel operation similar to other devices, listed by BATFE as PADS. Other devices function as part of a larger whole, and rely on other interacting components, just as rocket motors do.6. ATF has previously exempted equivalent rocket motors used in aircraft safety systems from regulation. Details on these systems can be found at The proposed...

Oct 10, 2006 80 Replies

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Dave Grayvis 19 years ago

Then why are you still here?

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[Planet News] NAR/TRA Joint Statement on BATFE Issues, dated October 9, 2006

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