USR vs Aerotech

A factory in Tempe AZ. . . oh, wait, no, It Blew up a few years ago. ;-)

-Chr$.

If there is no treaty yes. If there is a treaty maybe still.

Point!

But they are in a hurry to selectively call SOME manufacturers ILLEGAL. And based on false basis too!!! ie LEMP despite 27 CFR 555.141-a-8 and their own pesky lawyers!

THEY (NAR/TRA)

Ray,

You have missed the point entirely, and at the same time re-iterated mine.

You don't know. I don't know. TRA doesn't know. There is so much regulation to wade through it's not possible to decalre someone "legal" or "illegal"

It's not this forum I worry about. It's the spambots that harvest the net looking for email addresses. Just posting an email address in a message, like snipped-for-privacy@ftc.gov is likely to result in sagans of unwanted email messages to that address. That's why I redirect mine to another planet :-)

Bob Kaplow NAR # 18L TRA # "Impeach the TRA BoD" >>> To reply, remove the TRABoD!

What about our most favored nation trading partners, Chinese prisons?

It's not that complicated. Either they have the manufacturing and shipping permits, or they do not. Both of these are supposed to be in place _prior_ to certification, so it's up to the company submitting the motors to make sure they are in compliance.

Because "it" is unknowable.

It being absolute compliance under the law.

You're right. It's not that compicated. They do have the permits. TRA ignores them arbitrarily. It's not that complicated. TRA is arbitrary.

AND up to the certification authority to recognize them when they do. Without the final leg in the line the whole deal fails. Over and over and over.

Jerry

Ray,

The problem is that no one is going to be able to cite anything. There is no law on the books that says "it is legal to accept a shipment even though it may have been packaged or shipped 'illegally'"

By the same token, there is no law that says "it is illegal to accept a shipment even though it may have been packaged or shipped 'illegally"

Laws are not written to tell you what is legal. They tell you what is not. 49 CFR tells us that it is illegal to ship hazardous substances in the US. Then it tells you what the exemptions are to the "illegality"

This is the same problem as with the process of testing for hazardous substances. As the testing is laid out, the substance goes through several tests. After each test, it either drops into a class or goes on to the next test, progressively falling from 1.1 to 1.2, to 1.3, to

1.4, to 4.1. If it passes the test that would drop it into the 4.1 category, there is no statement that says it is not hazardous. It just says nothing.

This is called compliance by exemption. The rules don't apply, so you are automatically exempt. That's how 27 CFR 555 works, also. Based on the definition of explosive, whether APCP is on the list or not, whether PADS are exempt or not, Hobby Rocket Motors are exempt. No request from BATFE is required.

Bob

This should be in the FAQ.

The frustrating thing is that some folks say there _are_ laws making it illegal. For instance Fred has stated on the TRA list that knowingly receiving improperly shipped Class 1.x "explosives" violates two federal laws. Fred, if you see this post perhaps you can give some specifics?

Ok, but doesn't the DOT have to approve the test results at some point? If they didn't, what would prevent someone from just claiming that their material fit into an unregulated (or less regulated) class? Does the DOT really just take the manufacturers and importers at their word and let them ship whatever they want anyway they want??

And as for dropping out of 1.x to 4.1 class, how is it possible that APCP from one manufacturer can be classed so differently from that of another?

That's exactly what the ACS report that Jerry presented is an example of: it records the "examination" (what tests were conducted, and what happened), and also the "classification" - this is where DOT "approves the test results" by interpreting them to mean that the material should be given a certain hazard class under certain circumstances.

-dave w

What if they DID, and issued an expiration free document, and changed their mind later?

Here is a direct quote from a DOT/BOE/AARR reg:

A specific series of tests determines the hazard classification. The manufacturer's knowledge of the material can, in some cases, substitute for some of the tests in this process. In the absence of assumptions, except a concern that the material is explosive, the material moves through Test Series 1 and 2 in that order. Test 1 looks at output ascertaining if the material exhibits explosive characteristics. If not, then for transportation classification, it exits from Class 1 consideration at this point.

The regs were written so a hick from the sticks with a prior approved material and a relationship with DOT by virtue of that, could self-classify "similar" items.

The regulations have been made so onerous since on packaging specs, UN alignment and about 10 other aspects that "hick from the sticks" has been outlawed in effect by the sheer mass of conflicting rules.

BUT. The regulations allow for it.

Thus if everything you ship is 1.3C then the packaging and labeling and training and placards do not change anyway, so it becomes practical still in some very narrow examples. It also helps that 1.3C is the DEFAULT class for propellants that are non-detonable and only after a series 6 test does it drop to 1.4.

However if a material passes all of the Test series 1 and 2 it drops out of "Class1" (explosives 1.1, 1.2, 1.3, 1.4, 1.5, 1.6) and goes into 4.1 flammable solid. Only then is the burning rate the issue. If it burns under 2.2mm/s then it falls out of 4.1 and there is no other hazard class. It is thus and therefore not hazamat.

Nothing to issue. No jurisdiction at all.

Back in 1986 the criteria was different and the material we tested under

3.3x36" fell out of class 1 and it did not burn at the higher flammable solid threshold of the time so it was not recommended for any hazard class by the DIRECTOR of the Bureau of Explosives. Handy, eh? Especially considering he had a government mandated monopoly franchise on the testing at the time.

Just Tech Jerry

Merry Christmas!

The SAME material from the SAME manufacturer can simultaneously be 1.3C,

1.4C, 4.1 and unregulated as the company invests in ever more expensive testing to PROVE it is safe.

Each level is issued a hazard class if you want.

He cannot read and understand english. He is not alone. TRA has that problem as well as NAR.

I don't think it's drifted from that understanding.

That had been one subject brought up in the past. Going to say China and purchasing motors made there. I was just wondering the likelyhood of such an event. I mean it's not as if everything else isn't going overseas for production.

It was just bouncing around my head why if fireworks come over from China, there isn't already approvals for other explosives. And if that's the case, wouldn't it be cheaper to make them there, possibly even the casings?

Joel. ph

WWYAMCWWYAMCWWYAMCAAHNY

I assume that line above contains the first letters of a popular christmas song ?

/ArtU

import/export

Dave W. wrote:

IA1HOS

Joel. phx....

LATW

regulations