When are motors to be de-certified?

reading that

indeed they did, Steve. They unilaterally assumed overriding jurisdiction despite the objections of the DOT, which created a world of problems for the imminent Fourth of July celebrations.

excerpted from "Railroads To Resume Shipment Of Fireworks and Explosives" at

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:

"Sensenbrenner made an impassioned plea to the Department of Justice, Department of Transportation, and Department of Homeland Security to resolve their four-month interagency dispute over the shipping of explosives by rail."

ultimately, the Dept Of Homeland Security, Transportation Security Administration issued a notice rescinding SEA WRT rail transporation.

In summary:

"the transportation of explosives via rail by certain persons described under the SEA does not pose a sufficient security risk warranting further regulation at this time. Based on the determinations made by the TSA and the DOT that are detailed in this document, certain federal criminal provisions described below do not apply to persons while they are engaged in the commercial transportation of explosives by rail."

this established the precedent for overriding DOHS/TSA jurisdiction, with provision for coordination with the other agencies

"TSA was created following the terrorist attacks of September 11, 2001, as an agency within DOT. TSA was transferred to the DHS on March 1,

2003, and has statutory authority to set standards for security and make determinations regarding the adequacy of security in all modes of transportation. DOT agencies consult with TSA on transportation security matters. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) is an agency within the Department of Justice (DOJ), and has statutory authority to address, among other things, the manufacture, purchase, possession and use of explosives.

"Representatives of RSPA, FRA, TSA, and DOJ consulted extensively with each other to ensure that this document accurately reflects the security considerations relevant to those persons responsible for transportation of explosives in commerce by rail."

after all, the DOHS was formed specifically to manage security threats at home

see the complete record in the Federal Register at

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- iz

Reply to
Ismaeel Abdur-Rasheed
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Fred,

I don't understand your statement regarding TRA/NAR certifications not affecting your operations, given the following policy:

from

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"Our launches are not Tripoli Rocketry Association, (TRA) or National Association of Rocketry, (NAR) sponsored. However, you must hold the required high powered rocket certification from TRA or NAR to use and fly rockets using H or higher impulse motors."

or are you saying that you don't care about their _motor_ certifications, but just the _user_ certications? why don't you do your own user certifications independent of TRA/NAR, as you do launches. Then flyers could qualify for HPR flights at MDRA without TRA/NAR membership (esp. since you have your own insurance). Perhaps then even Brian can fly hos motors there (as a minor).

just honest questions, Fred, I'm not trying to hassle you.

- iz

Reply to
Ismaeel Abdur-Rasheed

childish :(

go away

- iz

Reply to
Ismaeel Abdur-Rasheed

KCs exposure of the fallacies in TRA helped bring scrutiny to bear on their actions, requiring their actions to address some issues

but being as they are, their actions were mere gestures and posturing

don't believe it Ray, its reality does not hinge on your belief

- iz

RayDunak> David wrote:

Reply to
Ismaeel Abdur-Rasheed

Iz,

When we were in the process of establishing MDRA, there was debate amongst the group; concerning individual certifications, minor issues, insurance, land owner liability considerations, and what our relationship would be with the national organization. As with most processes, the devil is in the details. I will try to briefly explain. BTW, this list is not all inclusive, but significantly representative.

Certifications: We believe individual certifications is a good concept, as it gives at least the perception of a structured environment, with a point of entry and a level of demonstrated progression. Also, as our members were individuals with TRA and/or NAR membership there is no reason to reinvent the certification wheel. In addition we did not wish to appear in competition with the national organizations, as that was never our intent.

As for as motor certifications; what a can of worms that would be. In reality, it's an economic and manpower issue. If done by volunteers from the organization, (MDRA,) who is going to except the mantel, we don't have the membership to staff such an undertaking. If you consider independent lab certification, we can't support that, it costs money and manpower.

Minors: Because of the way individual legal liability is established by age, we adopted the same age restrictions the national organizations use. This decision was made with the recommendation of legal council.

Insurance: This issue started the MDRA train in the first place. Several years ago when insurance renewal threatened to impact the ability of TRA and NAR to provide insurance for launches, we decided to fix the problem once and for all. As you know, there is no desert BLM land available in the east and most launches are on private land. Leads me to the next issue.

Land owner liability: MDRA is fortunate to have four launch sites. Protection of the land owner is "job one". Every decision made then and now, is made only after asking, "how will this effect the land owner in general and specifically, is there land owner liability". Decisions are adjusted accordingly.

This is down and dirty and is my thoughts and explanation. As I said in the beginning, "The devil is in the details". However, our web page is an open book and we don't hide behind an organizational firewall. There are links to all of our news letters and we invite all government agencies and anyone else to come take a look.

BTW this is for some of you: I do not intend to respond to flaming or attacks on the integrity of MDRA or myself.

Fred

Reply to
W. E. Fred Wallace

Huh? Cato is not a hero and he is not a villan WRT TRA.

He did certain things. What he did is clear and on the record. Listing them is not hero worship. It is reporting.

Jerry

Reply to
Jerry Irvine

By "someone" do you mean the DIRECTOR of the BUREAU OF EXPLOSIVES, a government agency solely (at the time) charged with classification of civilian explosive materials in the United States of America?

Just checking.

Jerry

I assume, of course, you trust Bruce Kelly more.

Reply to
Jerry Irvine

Yes, EXACTLY as RECOMMENDED by the DIRECTOR of the BUREAU OF EXPLOSIVES.

Reply to
Jerry Irvine

May I? My equipment makes it a one or two person job and can be done AT LAUNCHES so people can see the "cool static test show".

Reply to
Jerry Irvine

thanks for responding, Fred :)

if a member leaves (voluntarily or otherwise) both TRA and NAR after achieving a L2, his cert will expire without continuous membership in those orgs. Would they still be allowed to fly HPR/EX at MDRA, or would you only accept "current" certs?

just an honest question. You are in the unique position of having your own policies, and I wonder if you have given this some thought.

- iz

W. E. Fred Wallace wrote:

Reply to
Ismaeel Abdur-Rasheed

Fred

Reply to
W. E. Fred Wallace

This subject was brought up for revision consideration in year two of the organizations existence. It was discussed at length for several months. In the end, it was decided not to change the national organization certification and national membership requirement. The prevailing argument: We would be speaking out of both sides of our mouth, if national organization membership and HPR certification was an initial MDRA requirement and later dropped as a requirement for MDRA renewal. Also, it was pretty much a moot issue sense 100% of MDRA members belong to one or the other national groups. I was one of those who argued the prevailing argument. Also, I see it as a snow ball rolling down the hill: I.E. the next request would be, "can I join MDRA and have my old cert level, I belonged to NAR x number of years ago, etc., etc.". Also, in the beginning and it still is the intent of MDRA, not to give the impression of competition with the national organization's certification and membership process. We believe we enhance the national organization membership numbers, by the policy we have in place.

Fred

Ismaeel Abdur-Rasheed wrote:

Reply to
W. E. Fred Wallace

thanks, Fred

while I have my own personal views on the issues you've discussed, I respect and support the freedom of MDRA to make its own policies.

I am considering MDRA membership and have some specific questions

REGARDING: MDRA's "Liability Waiver, Safety Code And Risk Disclosure" at

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"NOTE: You must be a minimum of eighteen (18) years of age, Class B Certified, holder of a current LEUP and LEVEL 1, 2 or 3 CERTIFIED to fly LEVEL 1, 2 or 3 rockets at this launch."

QUESTION: what constitutes being "Class B Certified"? Is that a distinction unrelated to the LEUP?

REGARDING: MDRA's "Membership Application Form" at

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"Membership in the MDRA will allow a member to fly sport rocketry or work on Certification of Levels 1,2 or 3"

QUESTION: how are these certifications possible at MDRA if the club is not a TRA Prefect or NAR Section? Or they done through Maryland Tripoli #68? Are all MDRA launches "TRA sanctioned launches" where certifications may take place, or does Maryland Tripoli have its own launch dates apart from MDRA?

finally, if you would briefly summarize other practices that distinguish MDRA from Tripoli Prefects that hold EX launches?

- iz

W. E. Fred Wallace wrote:

Reply to
Ismaeel Abdur-Rasheed

Mainly PI.

Reply to
Jerry Irvine

It is not competition to simply recognize an achieved level. Like a merit badge.

TRA seems to have no compunction at all about askig for ATF permits even though the NFPA code THEY AUTHORED does not require it. They should respect local rules. You certainly pose no national threat to them.

Reply to
Jerry Irvine

In light of 27 CFR 555.141-a-8 and the NAR/TRA lawsuit on same, MDRA should immediately eliminate the LEUP REQUIREMENT and make it strictly optional.

You only need ONE at a launch to make the entire launch legal even if you do believe it is a needed permit, which it is not.

Jerry

Reply to
Jerry Irvine

Iz, see responses in paragraph line.

Fred

Ismaeel Abdur-Rasheed wrote:

All of the above needs revision, "Class B Certified" is ancient terminology and we don't ask if an individual has a LEUP. However, we encourage or members to get a LEUP, if possible. For the most part, we have enough folks with LEUP's, some with storage, and LEUP's has not been a problem. Once again, no one will ask an individual at the launch if they have a LEUP, much less refuse them to launch regulated motors. I have on more than one occasion, purchased a regulated motor, logged it into my record, and the individual launched there rocket. I even talked to the ATF about this practice and my agent had no problem with the practice, as a record of purchase and expended use was covered in my log.

Let's just say, we have Prefects and TAP, including myself as members of MDRA, who can provide TRA certs. Take a look at the membership listing, you may notice several names that fall into that category. If you look close enough, you may notice a TRA BOD member. In addition, we have NAR members that work the L1 and L2 NAR certs. We also have one NAR LC3, (or whatever they call it) individual, who is a member of MDRA. So far, I believe certing at MDRA launches is a win-win for the national organizations and to my knowledge, it is not an issue for either. Although we are an open organization with no organization information fire walls, we also realize our activities and policies could be a hot button issue for some national organization members, so we don't rub any noses in it either.

This is a response quoted below is from a previous post. I believe it answers your question, but in short, we mix and match commercial and certified motors on the same day. TRA, on the other hand, will not allow the same type of activity:

As anyone else, you are welcome to join MDRA; and use high power rocket motors that meet the following criteria, within your, TRA/NAR, HPR certification level:

  1. Commercial motors known to be legally manufactured. We obviously know whom the legal manufactures are.
  2. Motors, you indicate as an individual and/or group of individuals present at the launch have made. We may ask an individual and/or group the question; "who made the motor?", However and for the most part, our RSO will not question the registered flyer's answer and will allow the motor to be used if the answer is; "I made it or we made it".
Reply to
W. E. Fred Wallace

I hope this repost below, covers your concern, rest assured, i will address the needed revision:

All of the above needs revision, "Class B Certified" is ancient terminology and we don't ask if an individual has a LEUP. However, we encourage or members to get a LEUP, if

possible. For the most part, we have enough folks with LEUP's, some with storage, and LEUP's has not been a problem. Once again, no launch official will ask an individual at the launch if they have a LEUP, much less refuse them to launch regulated motors. I have on more than one occasion, purchased a regulated motor, logged it into my record, and the individual launched there rocket. I even talked to the ATF about this practice and my agent had no problem with the practice, as a record of purchase and expended use was covered in my log.

Fred

Reply to
W. E. Fred Wallace

Cato's escapades have been hashed and rehashed plenty of times, there's no need to go over it all again. He's not worth the effort. Those who think he's some kind of martyred saint will always think so regardless of anything I say about it. And I've yet to see any reason why I should change my opinion of his actions.

Reply to
RayDunakin

What, precisely is a "regulated motor"? Is it a formal position of MDRA? Is it a formal position of Fred Wallace?

Jerry

Reply to
Jerry Irvine

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