It's not their job to interpret law for you. TRA/NAR are neither lawyers nor AHJ's. Frankly, I've never understood this desire to have some official TRA/NAR "interpretation" everytime they think there's something vague in some law. If you're so worried that you might do something that is technically against the regs, just don't do it. It's that simple.
TRA/NAR could tell you their idea of what it means, but your local AHJ may have an entirely different interpretation. And asking the AHJ's tends to make the situation worse, as they generally will take the most restrictive view just to cover their butts.
Did you read it? It specifically defines "manufacture" as the "preparation of propellent, delay and ejection compositions".
Of course, it includes "loading and assembly", which could be interpreted to mean that you can pre-load your H128 at home before going to the launch. Not that I think anyone needs to worry about it, just thought I'd mention it.
Way back when, didn't NAR/TRA write the 11XX NFPA code as we see it today? If it wasn't their "job" to "interpret" It seems to me it wasn't their "job" to write it in the first place?
well Ray I was always told to go to the source if I had a question baout something... You would think that since NAR/TRA esssentially wrote the NFPA codes, they would at least be in the best position to know what they meant? I mean the only alternative as I see it and a very poor one at that, is to allow 50 different State Fire Marshalls all interpreting the code as they see fit too... Isn't that one of the major reasons the NAR/TRA sued the BATFE in the first place because you had different ATF field offices interpreting the law one way and other field office differently? Sounds like chaos to me...
ji: so lets see, instead of you answering my post and showing where it doens't apply, you now challenge me to provide evidence and support that it does? in essence you want me to answer my question for myself? wheres the fun in that?
Yes, but it's their opinions that count, since they are the AHJ's. NAR/TRA could tell you what they think it means, or is supposed to mean, but their opinions don't have the force of law.
Personally I'd rather have a little ambiguity anyway, it gives you some wiggle room. If you're not comfortable with wiggle room, don't wiggle. Problem solved.
Our State congress critters are basically lazy (in PA, don't know about the other 49 states) they write easy laws that reference that NFPA code and now NFPA code is law, therefore, "NAR/TRA opinions, and what NAR/TRA think it means" now has the force of law! When a state references NFPA or adopts it by legislation it's the law, so any ambiguity, turf wars, territory claims, political BS, and poorly thought out schemes written into the code that becomes law and has the force of law. But you knew this. Right? In my opinion, the NAR/TRA, when generating NFPA code, HAVE AN OBLIGATION to write the code with no ambiguity and with a little bit of wriggle room that is heavily slanted toward the rocketry side of fence. NAR/TRA better understand what they code up, make sure the future negative consequences of that code is non existent or close to it. They volunteered, it is their obligation to be prepared to make changes to the NFPA code to correct the portions of NFPA code that causes grief. They are involved and have no choice but to monitor the consequences of NFPA to the rocket community. If the code has problems, causes problems, NAR/TRA better get to it soon. I'm sixty and I don't want to take half a day movin' my walker and HPR rocket to a launch pad before changes are made.
Problem is not solved. The wiggle room of interpretation now belongs to the State and local AHJ's. The clubs, and individuals are now left with a fight over the ambiguity of interpretation with AHJs, which always includes a monetary hernia to move the bureaucratic inertia in our direction.
Is this true - NAR/TRA, sits behind "It ain't us anymore ,it's the States and local AHJs" ...yada-yada,BS more yada,yada etc? However, as you claim: "NAR/TRA could tell you what they think it means, or is supposed to mean, but their opinions don't have the force of law." I don't think so. (didn't this come up in the '90's )
That's true of any law. Only the AHJ's and courts have the power to interpret law and make their interpretations stick. I could give you an interpretation, the guy down the street could give you one, NAR/TRA could give you one, but the ONLY one that counts is the interpretation of the AHJ's and courts.
If you had a conflict with your local fire marshal, would he be swayed if you told him that TRA/NAR disagrees with his interpretation? No way! Nor would a court.
So far I don't see anyone in the hobby fighting with AHJ's over interpretations of NFPA code. I do see hand-wringers in the hobby who insist that they have to have an "official" statement from somebody before they'd even wipe their own butts. As I've said before, if an individual isn't comfortable with the "wiggle room" in the code, they should stick to doing only what they are comfortable with.
NAR/TRA are those local AHJ's in most cases. Remember, RSO is god.
Why did you think the various government agencies put up with TRA/NAR's illegal logging of exempt motors for so long? They "were supposed to know what they were doing".
Little did they know the leaders of those clubs are morons who cannot read and follow the law.
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