pros and cons list for Pro38 and Aerotech engines.

checkmate.

Too many false things to pick out. BS

Apparantly not all for THREE such sumbissions.

Ask TRA for a list of any submissions made and NOT approved for any reason. Just the Mfg and the Brand and date involved.

If they include all contacts where documentation was OFFERED whether or not it was "processed" or approved, you will find a long list.

Jerry

One of the TRA arguements to exclude Jerry was address of manufacture. That is why the counterclaim keeps coming up WRT Aerotech and Ellis not because of a DOT law or rule.

Jerry

According to past TRA rulings when Jerry was standing there with hat in hand, yes.

This is NOT about launches. It is about LEGAL multi-state market access at all, even outside TRA and NAR clubs.

Did CAR?

They accept a WIDE variety of safety critical industrial products exactly on that basis. It is tests we are talking about. Accepting test results of standard measures like thrust, case temp, delay and ejection. Sdtandard stuff.

microparse

[ie any]

[Follows the rules.] [Specifically NOT limited at the inception.]

[AND NO REPORTING OR INDIVIDIUAL APPROVAL REQUIREMENT. N O N E.]

Jerry

The actual reason is they have no legal jurisdiction no matter what license applicants or the ATF says.

Jerry

I have a written exemption proof letter.

nope, he is not

first you should be aware that NFPA 1125 contains very elaborate requirements for a motor manufacturing facility, and I would expect that building permits, inspections and licenses to operate (if required) would fall under the purview of country or SFM, city and/or building departments.

apart from those, the only reporting requirements regarding new or changed locations are

• the permit issuer as per 18USC40 (where applicable), and

• the AHJ for fire safety

and, when required by 40 CFR, SARA, Title III, the

• the local emergency planning committee,

• the local fire authority, and

• the EPA

NFPA 1125, 2001 ed. (excerpted for editorial review)

-- Chapter 4 - Manufacturing Operations for Rocket Motors

4.2.2 The [permit as per 18USC40 where applicable] issuing authority shall be notified when required of any change of business name, controlling ownership, or address.

4.13.5 The authority having jurisdiction for fire safety in the locality in which explosive materials are to be stored shall be notified of the type, magazine capacity, and location of each site in accordance with 27 CFR 55.201(f). The notification shall be made verbally before the end of the day and in writing within 48 hours of when storage has commenced in accordance with 27 CFR 55.201(f).

4.13.6 The local emergency planning committee, local fire authority, and the EPA shall be notified of chemicals in quantities when required by 40 CFR, SARA, Title III.

Chapter 5 - Limited Quantity Manufacturing Operations for Composite Propellant Rocket Moto

5.2.2 The [permit as per 18USC40 where applicable] issuing authority shall be notified when required of any change of business name, controlling ownership, or address.

5.12.5 The local fire authority shall be notified verbally before the end of the day and in writing within 48 hours of the commencement of storage of explosive materials in accordance with 27 CFR 55.202.

5.12.6 Local emergency planning committee, local fire authority, and the EPAshall be notified of chemicals in quantities when required by 40 CFR Superfund Appropriation and Reauthorization Act (SARA), Title III.

it appears that there is no NFPA 1125 requirement for a manufacturer to notify a certification authority (read, 'national organization') of any new facility for change of address.

however, if the new or relocated facility results in "manufacturing tolerances made to the physical design or chemical composition" being exceeded, those changes alone (and not the facility location) must be reported as per

8.1.6 Any changes exceeding manufacturing tolerances made to the physical design or chemical composition of a model rocket motor, motor-reloading kit, or component(s) by a manufacturer after certification testing shall be reported to the authority having jurisdiction, a recognized testing organization, or both, prior to sale or shipment.

8.2.6 Any changes exceeding manufacturing tolerances made to the physical design or chemical composition of a high power rocket motor, motor-reloading kit, or component(s) by a manufacturer after certification testing shall be reported to the authority having jurisdiction, a recognized testing organization, or both, prior to sale or shipment.

I'm sure ...

- iz

Ismaeel Abdur-Rasheed wrote:

Sure, an athority to """"""certify""""""" motors either for each or for all states. But those motors could still be denied use at "my" launch because of reason 'Y' (today).

Sounds like you're all set then. Start with an 'easy' state and get motors on the shelves.

Joel. phx

But only (IIUSTFATHBPINPBHAV) because that address was different on each. Business ID, EX numbers LEUP,... should a manufacturer not have the same business name and address on each?

Is there any question that AT has(had) that for their facility? Is there any question that EM has(had) it for theirs?

Joel. phx

No it wasn't. They were ALL aligned.

Does it have the name, jerry irvine on it?

How about we ask you. Show us this list. TRA isn't here.

And what was the address of manufacture?

Asking for handouts?

Perhaps you're right. (I don't have access to NFPA 1125/1127). But obviously these other companies are making and selling motors somehow, and doing it without NAR/TRA certification. (Not just "big" companies like Thiokol either, but also companies that make smaller rockets for line throwing, parachute deployment systems, etc.)