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Re: Commercial motor manufacturing

Since you are already a proven liar and inherently incapable of adding any value to rmr discussions yourself (citing today's Kosdon comments), let me rejoice in proving you a liar yet again.

From: Rick Dickinson

All I have been saying is that:

1) The judge ruled that fully assembled rocket motors are, for now, correctly classified as Propellant Actuated Devices (PADs), as listed in Title 27 of the Code of Federal Regulations, Part 555 (formerly known as Part 55), Section 841(a)(8). 27 CFR 55.841(a)(8), in full, reads as follows: "(8) Gasoline, fertilizers, propellant actuated devices, or propellant actuated industrial tools manufactured, imported, or distributed for their intended purposes.". 2) 27 CFR 55.841(a)(8) is only one of 9 exemptions mentioned under 27 CFR 555.841(a), which reads, in full: "(a) General. Except for the provisions of Secs. 55.180 and 55.181, this part does not apply to:" 3) The term "this part" in 27 CFR 55.841(a) has a specific legal meaning, in context. It refers, specifically, to the particular Part of the particular Title containing the phrase "this part". In other words, it refers to Part 55 of Title 27 of the Code of Federal Regulations (aka 27 CFR 55). This reading is made even more obvious by the fact that the sub-section 841(a) mentions several other sections within the part it's talking about specifically by number. 4) The provisions of sections 55.180 and 55.181 relate to "plastic explosives", which are defined in 27 CFR 55.180(c)(4) as "(4) Plastic explosive means an explosive material in flexible or elastic sheet form formulated with one or more high explosives which in their pure form has a vapor pressure less than 10-\4\ Pa at a temperature of 25 deg.C, is formulated with a binder material, and is as a mixture malleable or flexible at normal room temperature. High explosives, as defined in Sec. 55.202(a), are explosive materials which can be caused to detonate by means of a blasting cap when unconfined." 5) I don't think anyone has ever even alleged that the rocket motors we are talking about are "formulated with one or more high explosives", so the provisions in sections 55.180 and 55.181 of this part (part 55) are clearly not applicable. 6) Since 27 CFR 55.180 and 55.181 are clearly not applicable, what we are left with is an exemption from all of 27 CFR 55. As you can see by perusing
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, Part 55 regulates all aspects of "Commerce In Explosives", from licensing to storage, to disposal, transportation, or what to do if any is stolen. See 27 CFR 55.41 for general information on Licenses and Permits, for instance. 7) An unequivocal exemption from essentially all of 27 CFR 55 (with the twin exceptions of the sections relating to plastic explosives I mentioned above) means that LEUPs are not needed. It also means that LEMPs are not needed for manufacturing PADs. Assembling a PAD is an unregulated activity, at least as far as the federal explosives regulations in 27 CFR 55 are concerned.

==

Jerry:

Dave W:

Well, the storage requirements are in part 55 (now 555), along with the permit requirements... the whole "part" falls under the scope of the various exemptions given at section 141.

-dave w

PRECISELY.

Gold star!

==

"I have to agree with Jerry on this one, his posts are on topic. When a newbie asks about a LEUP, Jerry simply points to the law, sure he does a great broken record imitation, but then somebody has to or the so-called "pundits" would have every poor sucker looking for an H motor bend over and crack a smile for the BATF."

- Jim Rutkowski, Executive Chef,

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"I apologize Jerry. You are correct as usual.. "

- Fred Wallace

"Brian Teeling is a liar."

-Jerry Irvine

Reply to
Jerry Irvine
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jerry, the question was, "Prove to me that you can manufacture a substance on the explosives list without a LEMP". you have not answered that question.

By the way, do you have My judgment money?

Reply to
Dave Grayvis

Once again proving you cannot comprehend english. The explosives list itself is one of the things exempted since it is an element of "Part 55".

:)

Reply to
Jerry Irvine

So you are saying, there is no explosives list?

And, do you have My judgment money?

Reply to
Dave Grayvis

The applicability of the "list" is linked in by way of a definition within part 55.

That would fall under the exemption at 55.141: "this part shall not apply with respect to..."

-dave w

Reply to
David Weinshenker

Once again, please read and comprehend.

The explosive used in constructing PAD is not classified as PAD exzempt until used and assembled into the PAD configuration. As a result, the manufacture of the PAD, must have a LEMP or equivalent; because at a minimum, they either use the explosive propellant or manufacture the explosive propellant, used to construct/manufacture the PAD. I have talked to two different PAD manufactures in the aircraft parts industry, (Walter Kiddie INC. was one manufacture), and that process is the industry standard, regulated process, period.

Also, as for as DOT is concerned, a PAD is not exempt from an original shipping hazardous classification, (1.1, 1.2, 1.3,etc), unless a specific shipping exemption has been granted. So, if an assembled rocket motor, classed as 1.3c, (PAD), is shipped by common carrier, it ships as

1.3c hazmat, period. Those are the industry standard DOT regulated rules.. Violate them, (DOT), and get caught, as "BIG FINE" did, and the DOT horn goes up the pipe at $40 gran a pop, (in his case).

Fred

Reply to
W. E. Fred Wallace

He is trolling and nothing more. You note he never posts original content, mere rhetorical question and public posting we have all seen before, before he ever arrived.

He has no value. That is consistent with my prior experience with Brian Teeling.

Hey Brian, did you piont out yet your own MOTHER was an aliby witness for me re the Kosdon garage fire?

It would make for a truly amusing story. Especially considering your repeated accusations I "did it".

Jerry

Reply to
Jerry Irvine

False. Intended use. PAD manufacturing is exempt per 27 CFR 555.141-a-8.

Also only AP under 45 micron is considered an explosive on the [arbitrary BATFE] explosive list. Therefore APCP containing under 45 micron AP is the only "explosive" APCP too.

Just Jerry

Tell me who and I'll read the law to them too.

Jerry

Reply to
Jerry Irvine

The police did not interview My Mother. If someone committed arson on your instructions, you would be guilty of arson also.

Reply to
Dave Grayvis

Yes, but manufacturing and handling processes for explosive mixtures prior to being assembled into PADS is not..

Like you reading your BS interpretation will prove anything; other than your moron status. Once again, read the above example of reality and comprehend, if you can. Although to expect such is an obvious stretch.. In any case, the last thing I want, is to have you call someone in the industry I work, using a phone number and individual reference provided by me. Remember, I know what a deceitful individual you are.

Fred

Reply to
W. E. Fred Wallace

He never will, because he can't.

Reply to
RayDunakin

Then it should be easy for you to contact some PAD manufacturers and find out how many of them don't have ATF permits.

Reply to
RayDunakin

Well, to be fair, you would haveto find a manufacturer of nothing but exempt devices, whose ordinary business didn't also include materials not exempt from the regulations on "commerce in explosives"...

There was an example in the BATF FAQ, IIRC: a manufacturer of consumer fireworks (exempt by another subsection of 555.141) does not need a license to make or sell them.

If he were _buying_ flash powder (a genuine Explosive Material), for example, and using it as an ingredient in the fireworks, he would need a _user permit_ (not a license) to engage in "Commerce in Explosives" as a purchaser and user of that material.

In the case of a composite propellant rocket motor, the "listed explosive material" only comes into existence when it is created in the fabrication process of an exempt device. It doesn't exist in the abstract, or in generic bulk form - only as mixed and cast in specific propellant slugs.

It's not like you can buy APCP by the barrel, log it into inventory, and then record its "consumption" in the motor fabrication process...

How would a manufacturer be expected to handle the paperwork for "inventory transactions" if he is mixing and casting his own APCP grains? Does he log each mixer batch into inventory and then log it back out as "consumed" when he pours the grains?

That wouldn't work too well... he'd have the batch sitting there starting to cure and getting harder to pour while he was carrying it in and out of the magazine and updating the logbook!

-dave w

Reply to
David Weinshenker

Do your homework Dave; I did mine. When you have talked to industry folks, let the group know what you found out. We can debate interpretation of the issue until hell turns to ice. BTW, fireworks have nothing to do with PADS.. You seem to be reaching for straws. I guess listening to Jerry's BS for so long causes that phenomena. (:-)

Fred

Reply to
W. E. Fred Wallace

They're subject to parallel exemptions at another subsection of 55.141.

-dave w

Reply to
David Weinshenker

Obviously, I don't feel that you proved it.

Reply to
Phil Stein

Jerry,

I agree. Send me some motors.

Reply to
Phil Stein

Fred,

I've been trying to communicate that to Jerry for a while but, now I believe him. I think you should too.

Jerry, since you are correct and not jerking our chains, please send us some motors.

Reply to
Phil Stein

That was just because you told her you would rat out her son on something else if she didn't testify for you.

Reply to
Phil Stein

True.., but not manufacture..

Fred

Reply to
W. E. Fred Wallace

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