[suicide] TRA baselessly invites ATF inside HPR

Why would you ask, I thought you had an answer for every question in the world?

Is this a test, if so who cares?

As you're apt to do... Please cite.

Guess you'll have to go to Alaska to get the state's Attorney General to supeona the minutes. ;)

Doug

More Jerry-drivel:

Once again Jerry, you are confusing cause and effect. TRA's requirement that motor manufacturers provide proof of ATF manufacturing permits did not cause ATF to regulate APCP. The ATF required LEMPs for manufacturers prior to this.

It caused manufacturers and dealers of EXEMPT materials to seek permits and storage for materials that were clearly exempt as shown by the law itself, by the lawsuit NAR and TRA filed against the ATF and by written ruling of lawyers working the case. Lawyers are ANAL, so to take the position that 27 CFR 555.141-a-8 exempts all PADS takes a near miracle of legal clarity

Nope and you are FAR from an expert. I can state clearly they did NOT.

Jerry

Jerry, if your argument that APCP is exempt because motors are PADs, then manufacturers still MUST have an LEMP. Of course dealers would not need them based on a-8 once they were manufactured. Is there another reason why manufacturers need not have LEMPs (besides the fact that APCP doesn't function by explosion)?

Joel. phx

APCP has been on the list since 72, yes?

Based on what? The exemption is as broad as it could have been written.

The exemption only says _PADs_.

Joel. phx

I am not arguing other items. PAD only shop assumed.

The manufacturer MAKEs pads, until then no exemption.

Joel. phx

I wonder how many manufacturers of PADs (other than rocket-related PADs) have LEMPs?

If the ingredients before mixing are not regulated as explosive, and the process produces PADS, then the entire process doesn't need an LEMP, as the manufacturer is not making Low Explosives, he is making unregulated PADs.

~ Duane Phillips.

I would expect any one that ALSO makes or uses regulated explosives. Rocketry happens to not need that.

I for one would like to keep it that way.

Excuuuuuuse me.

The fact remains: the materials before creation are exempt. The end product is exempt. The waste and scrap of the process is not the regulated issue. No LEMP.

~ Duane Phillips.

I see - so "propellant" for "propellant actuated devices" is considered an "explosive" until the device is finished?

-dave w

APCP is on the list of explosives. What if they bought it pre-made then inserted it into the liner and slotted (if you could do such a thing,...). Would they not need to be licensed to handle it (not a LEMP in that case..)

I don't know, what does TRW airbags and that plane rocket deployed chute qualify as during manufacture?

Here's an idea, let's get this great group of people that reached into pockets and piggy banks for the suit and all that advertising to donate to actually test the stuff by several world wide recognized labs and federal agencies. Motors from every vendor willing to hand over samples. We could even have a range of particle size and formula mixtures to set some boundaries if that's an issue. Then we will have some paperwork that everyone can use to say IT DOESN'T FUNCTION BY EXPLOSION and possibly reduce shipping issues. We could also consider other countries regulations and attempt to accommodate those as well.

What do we need to do to make it happen? Would the Flynow people be willing to coordinate as part 3 or 4 of the effort?

Joel. phx

In theory you could make a "slurry" APCP and use it for blasting at your mine. I suppose THAT must be what they intended because obviously they also made the PROPELLANT when used as intended "to have a WIDE SWATH exemption with a record number of "or's" in the sentences.