It is HYPERCRITICAL the questions be raised WITHOUT either supporting cites (which could be researched and refuted) for its alleged invalidity and WITHOUT any clarity of answers to the questions. This is HYPERCRITICAL to the TRA/NAR position that the unanswered questions themselves make the papers invalid even though ON THEIR FACE (as intended to be used) they are clearly valid and do not expire.
The perfect, central example of FUD (Fear, uncertainty, and doubt).
None of your business. Are you an existing customer about to receive them? Are you a certification authority? Are you a recognized Competent Authority? I thought not.
Even errortech does not have to give you that stuff (but does in some narrow cases anyway) when they ship with exemptions.
That's about right, if not an understatement.
NAR refuses me on arrival. The papers do not matter.
I don't see why not. You have seen how Bundick acts toward me right here on rmr and you have third party testimony and evidence I am shunned by NAR (Gassaway, minutes, Bundick, other board members rare posts, a wide variety of things).
I called Chang and for only $3000 (a pittance) he offered to resubmit the report essentially as is. He warned that it was likely to "replace" the prior series, which had a recommendation that some items not even be assigned a hazard class, a recommendation DOT followed TO THE LETTER AT THE TIME to their later (1991 purge) shagrin, and DOT was likely to assign an explosive hazard classto any amount of APCP covered in the test from 0.00000001 g to 1000000000000000 KG.
I felt that would be "unhelpful" to quote our illustrious government.
So I went the route of entirely new testing with entirely new papers and entirely new EX numbers so I would always have a fall-back plan which frankly has saved my ass more than once on industrial and military deals in the past 10 years. They recognize a valid BOE test report when they see it and the military LOVES to classify their own material and does so in such a way as favorable to them as possible. Too bad I cannot ship consumer motors using DOD paperwork :)
The following represents a summary of the July 31- August 4, 2003 NAR Board of Trustees meeting in Henderson, KY. The Board met for 23 hours, considered 31 separate member inputs, reviewed 6 committee reports and made personnel assignments for 11 active committees.
The Meeting was called to order. Present were: Jennifer Ash-Poole Jack Kane Mark Johnson George Rachor George Gassaway Mark Bundick Steve Lubliner Stuart McNabb Trip Barber joined Saturday evening.
And while I allegedly have your ear . . . .
Philip D:
First, having been in rocketry through most of the BATF battles (and then some), you know what kind of hell it can be to get a federal agency to definitively rule on anything. Much less do so in writing. And it is impossible when they are of the opinion that they you are in compliance and they have no need to issue any type of opinion.
Second, you are on the board at the NAR. How many times has the NAR issued requests NOT to contact one agency or another? Why were those requests issued? Because everyone knows that has any dealings with federal agencies knows it is always best to let sleeping dogs lie, ask forgiveness not permission, etc.
David Erbas-White:
I don't want the scant resources of the rocket organizations being used for things that their not required to do. Having additional requirements that are not in their purview requires additional resources, in all sorts of ways. Given the state of the hobby, the organizations should concentrate on what they MUST do, not ancillary things.
Jerry Irvine:
Stop asking manufacturers for LEMP unless specifically required by law.
Stop asking vendors and consumers to get LEDP/LEUP.
Start accepting 1.3C approved motors for cert based on the FACE OF THE CA/EX DOCUMENT.
Apologize to ACS-Reaction Labs for stating their motors were DOT 1.1 class (detonable high explosive) perthe 8-03 Board minutes of the meeting YOU attended.
And before you say something wacky like "I am not on the board" or "that is not my job function", you ARE a confidant of the board members generally. You are a "trusted member"of the NAR heirarchy. Fine. Do something positive with that and gain my strong kudos and support. Start with the short list above. I will be glad to help and cooperate any way I can.
Jerry
Same minutes asked Miller to work with me on NFPA. Have not heard a peep from him. Have him email me. (please)
I agree, this has to do with DOT process and acknowledgement, not JI specific docs or EX numbers. It is the handle of these docs in general for which these questions apply.
(which could be researched and refuted) for its alleged invalidity
I also agree that it is the TRA/NAR apparent stance that the answers to the questions are "No".
This is the primary point of contention. The point of go/no-go. What is the proper AHJ point at DOT to direct these questions, or better still, is there any precidence or DOT documentation that would lend significant "Yes" to the queries?
The name was the signatory on the BOE report Jerry provides.
Since he is still a valid tester, it is hard to refute.
The issue seems to be trying to force Jerry into more restrictive requirements, when he has a "get out of jail free" card.
The more I hear, the more I am perturbed at the NAR/TRA handling of this document. It could be their "get out of jail free" card too, and open the supply chain like never before.
The documents "speak for themselves". TRA knows that and this whole "redefinition of the debate" is meant to imply otherwise. Sometimes without even saying so, and sometimes while deflecting educated people saying so. The acts are intentional, not accidental or neglegence by TRA.
He has been asked this directly more than 10 times and has not addressed it. But he has implied in several ways it is not done but is required. Can you trust him?
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