When are motors to be de-certified?

Jerry Irvine wrote:


I'm sorry, I live on the east coast and am not aware of companies providing the service out west. Airtex Inc. and Airshot are local companies we use at work, for specialized hazmat shipping. Talk to Gary, I'm sure he can help you..(:-)

You have the cart before the horse........

Fred
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providing the

work, for

No, as I understood him, he is referring to handling one document at a time. No longer to be refused "en masse". IIRC, the EX number first.

~ Duane Phillips.
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Well da, the Ex issue must be resolve before shipping.
Fred
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On Sun, 14 Dec 2003 12:40:15 -0500, "W. E. Fred Wallace"

I think that we need to back-up a bit, first. The question, to me, seems to be "which of the hazmat requirements apply." Until that question is answered, then we are only speculating on what wickets Jerry has to jump through to "legally" ship his motors.
In the DOT regs, there is a test sequence identified that establishes the path that must be followed (49 CFR 173.56, 57, 58) to classify explosives. If you assume worst case, this is the place to start. It is concievable that a propellant could pass through that series of tests and drop out as nothing more serious than being a flammable solid (49 CFR 173.58(a) The criteria for assignment of class and division are as follows: (6) Not in the explosive class if the substance or article does not have significant explosive hazard or if the effects of explosion are completely confined within the article.)
The table (49 CFR 172.101) does not work well when things drop out of the test. Still trying to understand it.
Does the DOT recognize his test data that his motor propellant is a flammable solid? I understand his reluctance to publish official documents that may identify patented formulas. However, we, as interested third parties, cannot go much further in this area without more data.
Bob
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Ah, but you DO have the actual TEST RESULTS.
http://www.v-serv.com/usr/images/ACS.BOEreport.jpg

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA
Opinion, the whole thing. <mail to: snipped-for-privacy@gte.net>
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wrote:

Hmmmm. I gotta go back and read the laws again to see whether the DOT must accept this recommendation or if they have the option of defaulting to a higher class if they wish.
So the next step is some documentation that the DOTaccepts the recommendation and acknowledges the classification of 4.1.
Bob
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wrote:

From 49 CFR 173.56(b)(1) "The person requesting approval of the new explosive must submit to the Associate Administrator a report of the examination and assignment of a recommended shipping description, division, and compatibility group. If the Associate Administrator finds the approval request meets the regulatory criteria, the new explosive will be approved in writing and assigned an EX number."
Key here seems to be, IF the AA finds the approval request..., THEN...approved in writing and assigned EX number.
Jerry, what is the relationship between the above BOE report and your ACS EX that you have let us see? Is it direct?
Bob
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But if it does not meet the regulatory criteria (on the low end) it requires NO REPLY OR ACTION including issuing a CA or any number at all.
Show me otherwise please.
And before you say 4.1 are issued CA's, that is itself new. They used to "drop out" of the process entirely.

yes.
--
Jerry Irvine, Box 1242, Claremont, California 91711 USA
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Bob, You have hit the problem square on the head. As I understand it, DOT has the option, to within reason, move up or down on classification. An example: All AT composite propellant is classified as 1.3. However, DOT grants an exemption classification of 1.4 for shipping, for the so called, "Easy access". Another example and I don't understand it: Some squibs used for blow down bottles and fire suppression systems, in the aerospace industry, have classifications that run from 1.3 through 1.4. I remember one unit that was 4.1. I have never done research as to why, but I suspect the difference has to do with amounts of energy producing compound and configuration of the device.
Fred
baDBob wrote:

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Yes. For natural class and exemptons too.

The exemptionisNOT theexampleIamciting atall.
Dothey have theoption to RAISE the hazardclass1or 2rungs HIGHER?or 4?
1.3 as assumed in 2003 despite a 1986 report to the obvious opposite 1.4 1.5 1.6 4.1 as tested and as issued by default (under3.3x36") 5.1 oxidizer
That is a difference of **4** hazard classes!!!!!!!

One was TESTED and received an ARTICLE approval as 4.1 and the remainder were classified by ANALOGY to the default hazard classes by general hazard and NEW (mass).

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA
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I will save you the trouble. They have the option. But they ACCEPTED the RECOMMENDATION VERBATIM.
Here:
http://v-serv.com/compliance/images/EX2.jpg
This year in an administrative matter they post facto claimed they exercised the option in a way NOT supported by the prior correspondence. They lied.
In fact the material not recommended for a hazard class was treated this way in 1986:
http://v-serv.com/usr/ATFexempt.htm
"Proper transportation hazard classification for an explosive, of course, culminates with the assignment of an EX Number. Much more specific than a Hazard Classification, an EX Number applies to a particular explosive formula and its packaging. The two larger pictures of historic regulation of explosives and the present system of classification of all hazardous materials are needed to make clear the EX Number. In the nineteenth century the EX Number was essentially a privately administered classification of the only recognized hazardous material. Today it is administered publicly as part - albeit a special part - of the larger system that regulates hazardous materials. 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." - TB-700.2 (DOD7002)[yet another authoratative government document, the 2003 version of which has been changed to add an "out" for the "out"]
Admittedly the treatment would be arbitrarily and capriciously different if tested in 2004, but it wasn't. Andclassification by analogy to ACS is available to EVERY APCP manufacturer who will listen to Jerry Irvine :)
I am your APCP god.

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA
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So Jerry, do you intend to do something about it, or continue to blame TRA and NAR?? It looks to me as if neither organization is, (once again), not your most pressing problem.
Fred
Jerry Irvine wrote:

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Did you forward that fax I sent to you with an appication for exemption to the DOT itself as you verbally told me on the phone?
If so on what date?
If sowhat was the titleor scaopeofthe document?
If so, what was their reply to you if any? Fax? May I have a copy? Phone? Who? When?
Thank you.
Bracketing in the facts before we divert to conclusions.
--
Jerry Irvine, Box 1242, Claremont, California 91711 USA
Opinion, the whole thing. <mail to: snipped-for-privacy@gte.net>
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Not only did I forward the fax, I had several phone conversations with Carol Monrow, resulting in me being contacted by a DOT investigator. I still have the package you sent me, that I forwarded by fax. It is in a file and I'm sure I printed and attached the fax report printout to the package. Maybe I'll scan it and post it to an open forum, as I have no intention of just faxing it to you. Check your old emails for dates, I know and remember that I sent you emails after the package was faxed.
I still find it strange, you never called or made contact with Carol at DOT. However, I have it from a pretty good source, the investigative arm of DOT contacted you after they received the package you provided me and I faxed to them.... Maybe I should give them a call and see what's shaking over at DOT, i.e. good old Bob... Would you like me to do that for ya Jerry????(:-)
Fred
Jerry Irvine wrote:

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Jerry wrote (about DOT): << In fact the material not recommended for a hazard class was treated this way in 1986 >>
Ok, so you're saying that the DOT has changed their policy? If that's the case, why blame TRA/NAR? They have no power over the DOT.
Fred wrote: << So Jerry, do you intend to do something about it, or continue to blame TRA and NAR?? >>
Oh, but it's so much easier to blame TRA/NAR than to actually do anything about meeting (or changing) the DOT's current requirements.
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how did an altered ACS DoT document, originating from a AeroTech fax machine, find its way into the approval process, Ray?
- iz
RayDunakin wrote:

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snipped-for-privacy@aol.com (RayDunakin) wrote:

5 times?
Because they actively ignore a valid government issued DOT piece of paper placed in front of their face, and also take one they got issued from Aerotech regarding ACS (a competitor) and use it as the one and only document they recognize, except it is obvious to the casual observer it has no merit whatsoever.
Did you know Sue McMurray told a couple of prospective motor vendors they had to get Aerotech's permission to sell reloadable motors? Yep. She sure did. And refused to talk to them further till they had it in writing!
Every time I post a new detail it just gets better and better,eh?
I've got a bunch of 'em.

I met them all along. And you?
Jerry
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Jerry Irvine, Box 1242, Claremont, California 91711 USA
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and
your
Actually they are the reason there is a problem in the first place. They require things they should not, and they woke the sleeping giant in the process for reasons the sleeping giant does not understand, nor care about. TRA moreso.
~ Duane Phillips.

course,
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You may be right, but the sleeping giant would of awakened sooner or latter.
Fred
Duane Phillips wrote:

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THAT is your excuse to personally do it today?
Moron detector!!!

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA
Opinion, the whole thing. <mail to: snipped-for-privacy@gte.net>
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