USR vs Aerotech

The BATFE will argue this point with you. For reference, look at air bags.

From ATF Explosives Newsletter June 1997:

"In order to obtain the explosive material used in the airbag initiators and produce the initiator for installation into an airbag unit, a license as a manufacturer of low explosives is needed. If manufactured initiators are purchased from an out-of-state source for installation into an airbag device, a Federal user of low explosives permit is required. Once the explosive material has been incorporated into the airbag device, it may be exempted from regulation."

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Reply to
David Schultz
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Both of you are acting in a way directly detrimental to rocketry as a whole.

And enjoying every moment of it.

You both suck.

Your parents should be ashamed.

Jerry

"Everything should be made as simple as possible, but not simpler."

- Albert Einstein

"Actually the reverse is true. Both Jerry and Bob contribute to this news group in a positive way. I don't always agree with them, but that's beside the point. It is you, Mr. Dunbar, that is guilty of blowing gales of hot air, posting off-topic messages, and posting nasty messages."

- Wolf

"Back in the '60s, there was an organization that brainwashed a lot of folks into believing that only 'gods' could deal with rocket motors"

- John Cato

and the last word on Fred Wallace and Jeff Taylor:

"False words are not only evil in themselves, but they infect the soul with evil" - Socrates

Reply to
Jerry Irvine

OK, here's a theoretical curve ball.

NAFTA supposedly removes restrictions between trade US/Mexico. Joe Blow opens a plant in Mexico to make motors. He's not under US jurisdiction so he CAN'T get a LEMP. Jim Blow (his brother ) wants to buy motors from Joe and sell them in the US. How would TRA handle this?

David Erbas-White

Jeff Taylor wrote:

Reply to
David Erbas-White

In what sense? My understanding may be incomplete, but a LEMP is tied to a location and a particular person or group of persons. If the company were sold, and remained in business at the same location then the new owner(s) would need to be added to the LEMP. If the location changed then a new LEMP would need to be issued.

-JT

Reply to
Jeff Taylor

Not to be an "anonymous troll" here but the gentleman (or lady--damned anonymous posters!) asked specific questions in the original post. Since I have actually waded through this entire thread and am therefore in a mild stupor I have a question of my own--

Has anyone actually answered the questions?

Reply to
NaCl

:Fred said

Let me know the next time your in the DC area, I'll set you up with a tour of my work stations; Maybe even get you a tour of Air Force One.

Fred

Reply to
W. E. Fred Wallace

I don't think so? I was wondering that myself?

Bayourat

Reply to
Bayourat

Just a little touchy tonight Jerry (:-)

Fred

Reply to
W. E. Fred Wallace

49 CFR 171.8

Person means an individual, firm, copartnership, corporation, company, association, or joint-stock association (including any trustee, receiver, assignee, or similar representative); or a government or Indian tribe (or an agency or instrumentality of any government or Indian tribe) that transports a hazardous material to further a commercial enterprise or offers a hazardous material for transportation in commerce. Person does not include the following: (1) The United States Postal Service. (2) Any agency or instrumentality of the Federal government, for the purposes of 49 U.S.C. 5123 (civil penalties) and 5124 (criminal penalties.). (3)Any government or Indian tribe (or an agency or instrumentality of any government or Indian tribe) that transports hazardous material for a governmental purpose.

Definition: assignee SYLLABICATION: as·sign·ee PRONUNCIATION: AUDIO: -sn, s-n KEY NOUN: 1. A party to which a transfer of property, rights, or interest is made.

  1. One appointed to act for another; a deputy or agent.

Bob

Reply to
baDBob

I did.

Reply to
Jerry Irvine

27 CFR555.141-a-8

27 CFR555.141-a-8

27 CFR555.141-a-8

27 CFR555.141-a-8

Reply to
Jerry Irvine

They authored them They adopted them

Reply to
Jerry Irvine

If your motors were certified, I'm sure you would be specific about which cases they are allowed to be used in as well.

-- Joe Michel NAR 82797 L1

Reply to
J.A. Michel

Geez...

If I wanted to get into the business of making popping widgets, I could go through the hassle of getting all the things I needed, or, I could go out and buy a company that already has the proper items, like a LEMP. A company is worth more to me with the LEMP, and therefore, it is an asset.

I didn't say anything about moving. The BATF requirement is that I notify them of ownership change and then continue on as normal, including going through the next renewal cycle.

Bob

Reply to
baDBob

I would be "required" to but I would list as many as possible so my propellant got used up faster.

But I guess we will never know.

Reply to
Jerry Irvine

Sure, I understand that. What I'm saying is that a LEMP is different than other assets, like patent rights for example. Buy a company and you instantly own the patent rights owned by that company. However, buy a propellant company and you don't instantly have a LEMP. At the very least you'll need to get your name added to the LEMP (including getting finger printed, etc.), and if you move the manufacturing location, then you are basically starting over again.

If you are not moving then the asset is a location and a facility that the ATF is already familiar with, which would make changing the LEMP to add your name trivial. It's still not a given, if something came up in your background that they didn't like, they could still deny you the LEMP. In other words, you can't buy a LEMP, but you can buy things (land, buildings, etc.) that will make getting a LEMP trivial.

-JT

Reply to
Jeff Taylor

Rockets built from a kit are OK for certification... what's not allowed is borrowing a rocket someone else built.

-dave w

Reply to
David Weinshenker

One might specify cases for liability reasons, or performance issues. If you're interested generating revenue on reloads and not hardware, then your approach has merit.

-- Joe Michel NAR 82797 L1

Reply to
J.A. Michel

Not quite true

Sec. 555.59 Right of succession by certain persons.

(a) Certain persons other than the licensee or permittee may secure the right to carry on the same explosive materials business or operations at the same business premises for the remainder of the term of license or permit. These persons are: (1) The surviving spouse or child, or executor, administrator, or other legal representative of a deceased licensee or permittee; and (2) A receiver or trustee in bankruptcy, or an assignee for benefit of creditors. (b) In order to secure the right of succession, the person or persons continuing the business or operations shall submit the license or permit and all copies furnished with the license or permit for endorsement of the succession to the Chief, Firearms and Explosives Licensing Center, within 30 days from the date on which the successor begins to carry on the business or operations.

Definition

assignee SYLLABICATION: as·sign·ee PRONUNCIATION: AUDIO: -sn, s-n KEY NOUN: 1. A party to which a transfer of property, rights, or interest is made.

  1. One appointed to act for another; a deputy or agent.

I'll give you the moving part.

Bob

Reply to
baDBob

How can (A) act as an agent for (B), when (B) no longer owns the goods? I must be missing something??? IMO, assignee as used in 171.8 is refering to a type of agent and is not applicable to change of business ownership.

Fred

Reply to
W. E. Fred Wallace

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