Want to do experimental motors but am NAR.

[Kelly]

I'm sure shipping stuff is out of the question for an individual, but the whole 'for profit' thing confuses me for sure.

It's simple - If you're selling something for profit, then without a doubt you are a commercial manufacturer, and would need to follow all pertinent local, state, and federal regulations. This applies whether you are manufacturing hot dogs, fidget spinners, or rocket motors. If you are manufacturing rocket motors then you had better believe that there is a long list of regs that you will need to follow, and you're not going to get working answers to what those regs are here, you're going to need a lawyer with experience in this field.

 

[prfesser]

I'm sure shipping stuff is out of the question for an individual, but the whole 'for profit' thing confuses me for sure. I'm not a fan of trying to play shenanigans with high shipping or other strangeness, but it seems to me the 'for profit' thing is what is causing that line of discussion. Is that an actual law or just a TRA rule?

It is a TRA rule designed to eliminate or at least minimize shenanigans by the unscrupulous who might want to manufacture motors or reload kits for sale at a profit. As Kelly points out, that would make the seller a commercial manufacturer, with all that that entails.

FWIW I just checked AT's site and the EMK do NOT contain propellant or epoxy; those are to be provided by the buyer. They are selling the same parts that they sell individually and in quantity. The EMKs are a convenience for the rocketeer who wants to make one or a very few motors.

And it isn't a matter of just buying an EMK and propellant grains. As noted on the site, the chamber pressures should be kept below 500 psi for model EMKs and 800 psi for high-power EMKs. The buyer will need to design the motor completely---grain type and length, core configuration and size, nozzle throat---to stay within those limits.

Also FWIW, the cost of a four-grain 75 mm single-use EMK and four Blue Thunder grains would be $350. A four-grain 75 mm L-motor runs about $400. Whether it's worth the $50 savings is questionable. If I was running AT I wouldn't provide a replacement for an EMK that CATOed or otherwise misbehaved; that's on the motor maker.

 

[Banzai88]

What if I were to buy all the same parts of a CERTIFIED motor a-la-carte (such as through the RCS web store), but NOT necessarily all at once....and then eventually assemble a motor, NOT from a single reload package, but in certified configuration?

Do I then have a certified reload, even though it's component parts were never sold as such?

 

[Steve Shannon]

What if I were to buy all the same parts of a CERTIFIED motor a-la-carte (such as through the RCS web store), but NOT necessarily all at once....and then eventually assemble a motor, NOT from a single reload package, but in certified configuration?

Do I then have a certified reload, even though it's component parts were never sold as such?

No

 

[jsdemar]

My post above gave the options from the point of view of the flyer, as the OP asked. As others have said, it gets more complicated when making propellant for someone else.

Two situations have caused the complications: changing the research rules such that the propellant maker doesn’t have to be present at the launch; and AT/RCS selling grains outside of certified motor packages.

The intent of not requiring the research motor maker to be at the launch was not to allow independent manufacturing. It was to cover the situation where a project team member couldn’t make it to the launch. As with any group project, costs are shared but no one is involved as a manufacturer of propellant as a service.

With AT/RCS selling individual grains, they are bypassing the certification required under NFPA 1125/1127. They are legal for shipping and transport because the propellant has been tested by a qualified DOT lab and has received exemption numbers from the DOT. But once the grains are used in a rocket motor at a launch, you are flying a non-certified motor with propellant not made by a member of the project group. This situation is not within the intent of Research launches.

The above is my personal interpretation and not as a member of the Tripoli Research committee.

 

[ksaves2]

One might make the argument that if one sells propellant grains that one made, then one is now considered a manufacturer. There is a lot that comes with that from NFPA, DOT and your AHJ. I believe that profit or loss from a sale does not change whether one is considered a manufacturer, and simply transferring the material [in the legal sense] seems like it would be equivalent to selling it from that perspective. A friend of mine went down this path with a business he started, ultimately it was pretty burdensome and that effort was abandoned.

If one really wants an answer to what all is involved, one could just call up Loki and ask someone who has done it.

br/
Tony

Scott Kormeier bought Loki from Dr. Jeff Taylor who already established Loki. Scott worked for him for a time then bought the business. I believe all of the manufacturing paperwork was transferred over to Scott as a result of the sale. That is different than doing a startup motor business from scratch. If I remember correctly, I think a heard Scott mention he had to take a government approved course on how to ship motor grains even though he'd been doing it with Dr. Taylor. Maybe Scott can correct me if I'm wrong on that. Also I remember him saying there was a lot of paperwork to go through to effect the business transfer to his name.
Again, there would be a lot more work with trying to do a startup to sell propellant grains from scratch. Shoot many small companies come and gone that have sold rocket parts and sometimes propellant. Remember Green Monkey Aerospace to name one?
My take on this is if one wants to mix, get someone to teach a course for a small group and enjoy the satisfaction of making a good motor to fly at Tripoli launches so designated that research motors are o.k. to fly.
Forget about going into business unless one wants to flush money down the toilet. Got a great red sparky? Post the formula so others who mix can enjoy it too if they want to try it. Starting a business from scratch and complying with all the laws can be daunting and expensive. Ask Jerry "He Who Must Not be Named". Kurt

 

[jderimig]

If you make an APCP grain and sell it someone else you are in commerce whether you make a profit or not. At that point you need to be in compliance with NFPA 1120 and DOT to be legal. Technically. If you make a grain that flies in the rocket your name should be on the flight card. How money exchanges hands within the project team members shouldn't matter. No rocket project ever makes a profit.

 

[tsmith1315]

But once the grains are used in a rocket motor at a launch, you are flying a non-certified motor with propellant not made by a member of the project group. This situation is not within the intent of Research launches.

Fuel grains 54mm and under from RCS look to be solid. For those motors, you design and create the core geometry. Nozzles are in various standard sizes, and may need to be drilled to your spec as well. I don't see any core dimensions provided by RCS/Aerotech in their tech drawings.

In those cases, would you agree that there is enough user involvement (assuming they are also the flier) to consider them a design member?


75mm & 98mm grains have a standard sized core. I don't see right away if core and nozzle dimensions must be provided by the user.

 

[Steve Shannon]

Propellants aren’t the only way to participate in research. What if you wanted to investigate different liner materials or nozzle designs? Being able to test those against a known propellant could be useful.

 

[ksaves2]

If you make an APCP grain and sell it someone else you are in commerce whether you make a profit or not. At that point you need to be in compliance with NFPA 1120 and DOT to be legal. Technically. If you make a grain that flies in the rocket your name should be on the flight card. How money exchanges hands within the project team members shouldn't matter. No rocket project ever makes a profit.

Hi John,
That's what Scott did. Complied, stayed above board with all the laws when he took over to remain legal.
I used to mix with a group and would bring some AP over to add to the mix corresponding to the motor grains I'd take home. No, money changed hands except when I bought the AP from the fellow whose shop we were mixing in previously. Purchasing AP powder is not an issue. Making grains for purchase is if the rules are not followed. That will get a party into a lot of trouble and hope the OP has sense enough not to do it or spend the money to be in compliance with the laws if he wants to sell grains. If the law is broken by "just" selling grains to one's "friends", if no one sings could get away with it. But that is hardly a profit making proposition with a limited market. Plus tick one flier off and they alert the authorities, that will be a bad situation for a seller to be in. If a seller is in compliance with all applicable laws the issue is between the dealer and the seller.
Very easy to tick someone off. Sell grains that CATO, destroy a case and/or rocket and one could get devastated by the authorities if a customer ratted out on a less than legal dealer. Like I said, I hope the OP doesn't try to go there unless he complies with the laws. Kurt

 

[PayLoad]

Every thread I have found on this subject always seems to degenerate into an imagination of some clown selling untested products from his garage who is willingly trying to circumvent any / all regulations regarding DOT / ATF / NAR / Tripoli. Can we look at it from another angle and get some input?

Can someone (who is following proper zoning, purchase requirements, manufacturing processes, business practices) Sell EMKs on the open market for use in Tripoli Launches? If not, How can RCS do so?

Why is this not a "yes" or "no" question?

 

[3stoogesrocketry]

I am ABSOLUTELY NOT trying to make waves, I am only trying to understand. But what you stated right there, completely, factually correct as it is, I see you in my head going "wink, wink"....

They are not called experimental motor kits of course, but they are all the parts needed to make an experimental motor, without calling it an experimental motor kit. Parts sold at a profit of course.

My question is, then, can somebody come up with a wonderful motor design, then just sell the parts without calling it an experimental motor kit? Even RCS states on each component what other parts it matches up with.

Not being argumentative, please, I just don't understand. It is no less than me giving away experimental motors, but charging $180 for shipping & handling to get around the "for profit" language.

First comment. Yes Aerotech / RCS sells everything you need to build your own version of their certified product , but no it is not a "certified" motor .

No , they are absolutely called EMK's (Experimental Motor Kit) and if you do some research , you see buying the parts and building your own motor is in fact cheaper most of the time .
Is there a reason a legitimate buisness charging profite for products the produce is wrong ?

No , someone cannot build a wonderful motor design and just not call it what it is . "Model Aircraft Parts" caused one manufacturer more then you would ever care to loose.

Hazmat is 45 dollars .

KIT = Un-assembled parts that, assembled, would make a complete motor. Exactly like what is sold at, say, the RCS site


Just curiosity at this point.

You seem to be confused as to how RCS operates. They sell EMK's , or experimental motor kits , see your post #9 as they do in fact call them this. All that is contained in these kits are INERT parts . That is all . I do not think $18.00 is alot for a single use 38mm full I baby J motor 38/720 size motor parts kit . If you choose to purchase a stick of fuel from RCS under 75mm , you must still cut and core your own grains , they are not pre packaged ready to go as you keep saying.

 

[Steve Shannon]

Snip…
Can someone (who is following proper zoning, purchase requirements, manufacturing processes, business practices) Sell EMKs on the open market for use in Tripoli Launches? If not, How can RCS do so?

Why is this not a "yes" or "no" question?

Yes.
An EMK contains no propellant.

 

[PayLoad]

I officially give up on trying to get an answer to this. You know what I'm asking.

Can This - https://www.rocketmotorparts.com/29...Experimental_Motor_Kit/p1577809_15297089.aspx

And this - https://www.rocketmotorparts.com/29mm_Black_Jack__Propellant_Grain/p1577809_10884768.aspx

Be sold together as an EMK on the open market for use in Tripoli Launches?

 

[jsdemar]

Propellants aren’t the only way to participate in research. What if you wanted to investigate different liner materials or nozzle designs? Being able to test those against a known propellant could be useful.

Yes, there are many technical challenges in motor making that do not involve making propellant. However, IMO, the end goal of Tripoli Research is to make your own motor with your own propellant (or with non-commercial propellant made by a team member who is a Tripoli member). If someone is at the point of researching liner materials, nozzle materials, etc, they should already have a reliable propellant formula and process for making it. The availability of commercial grains outside of NFPA 1125/1127 is what opens the loopholes we've been discussing.

An "Experimental Motor Kit" (EMK) sold without propellant is an excellent way for a Tripoli L2/L3 member to get into Research motors by concentrating on the propellant with fewer unknowns. Using an EMK with commercial grains has no value other than bypassing NFPA motor safety certification. The information for nozzle throat diameter and core diameters for AT commercial motors is available, so no design or "research" effort is required by the user. Again, this is my personal opinion and not as a member of the Tripoli Research committee.

 

[3stoogesrocketry]

I officially give up on trying to get an answer to this. You know what I'm asking.

Can This - https://www.rocketmotorparts.com/29...Experimental_Motor_Kit/p1577809_15297089.aspx

And this - https://www.rocketmotorparts.com/29mm_Black_Jack__Propellant_Grain/p1577809_10884768.aspx

Be sold together as an EMK on the open market for use in Tripoli Launches?

Yes you can use these to make your own version of H97J but it is still a EX motor. It will never be a certified legal motor . You can build and fly it IF you are level 2 or 3.

100 percent honest , I am confused as to what you really are trying to ask / do . If your trying to skirt around not being L2 but still fly EX motors ..... All I can say is , if the rocket weighs less then 3.3 pounds , and has less then 125g of fuel ( the H97 has 137g ) you can fly it out of your backyard legally .

 

[PayLoad]

Yes you can use these to make your own version of H97J but it is still a EX motor. It will never be a certified legal motor . You can build and fly it IF you are level 2 or 3.

100 percent honest , I am confused as to what you really are trying to ask / do . If your trying to skirt around not being L2 but still fly EX motors ..... All I can say is , if the rocket weighs less then 3.3 pounds , and has less then 125g of fuel ( the H97 has 137g ) you can fly it out of your backyard legally .

Whoa, I'm not trying to skirt around anything whatsoever. I do understand that I can fly the above as a Level 2.

The question, as straight-forward as I can make it -

Can Something Like This - https://www.rocketmotorparts.com/29...Experimental_Motor_Kit/p1577809_15297089.aspx

And Something Like This - https://www.rocketmotorparts.com/29mm_Black_Jack__Propellant_Grain/p1577809_10884768.aspx

Be sold together as an EMK on the open market for use in Tripoli Launches?

Pretend I wanted to have a legitimate business selling EMKs.

 

[prfesser]

Whoa, I'm not trying to skirt around anything whatsoever. I do understand that I can fly the above as a Level 2.

The question, as straight-forward as I can make it -

Can Something Like This - https://www.rocketmotorparts.com/29...Experimental_Motor_Kit/p1577809_15297089.aspx

And Something Like This - https://www.rocketmotorparts.com/29mm_Black_Jack__Propellant_Grain/p1577809_10884768.aspx

Be sold together as an EMK on the open market for use in Tripoli Launches?

Pretend I wanted to have a legitimate business selling EMKs.

Not unless you are a BATFE-licensed manufacturer of the propellant.

This whole discussion sounds an awful lot like the back-and-forth yes-you-can no-you-can't that has plagued discussions of "making motor starters".

And I'm outta here. Setting this thread to "Ignore".

Best,
Terry

 

[Steve Shannon]

Whoa, I'm not trying to skirt around anything whatsoever. I do understand that I can fly the above as a Level 2.

The question, as straight-forward as I can make it -

Can Something Like This - https://www.rocketmotorparts.com/29...Experimental_Motor_Kit/p1577809_15297089.aspx

And Something Like This - https://www.rocketmotorparts.com/29mm_Black_Jack__Propellant_Grain/p1577809_10884768.aspx

Be sold together as an EMK on the open market for use in Tripoli Launches?

Pretend I wanted to have a legitimate business selling EMKs.

Again, Tripoli cannot and does not regulate sales. I personally disapprove of selling those items together because of the optics.
I do not consider simply putting an EMK and readymade propellant grains together to save cost, with no real research goal in mind, to be within the spirit of Tripoli Research. That could ultimately put research rocketry in a bad light and cause problems for those who legitimately conduct research activities in an effort to learn more about rocket motors.

 

[PayLoad]

Not unless you are a BATFE-licensed manufacturer of the propellant.

But Terry, That was one of the more informative answers!

 

[Alan15578]

The ATF is no longer involved with APCP formulas. Sugar motors are a gray area and large BP motors fit some definitions for fireworks under the ATF, DOT, and NFPA 1123.

I don't know how all these laws fit in with rocketry and with the agreement for our hobby to regulate itself. As mentioned above, RCS sells grains and other supplies which can be assembled and launched at sanctioned Tripoli events as research motors. What's stopping someone from starting up a similar business? Say I have a fantastic red sparky motor that everyone has to have. Assuming a safe amd legal space for manufacturing, any reason I can't sell the grains for use? Or even apply for certification at that point.

First, I am L0 and an old MR competitor, so I appreciate the availability of high performance niche motors. I am also put off by the current high cost of certified motors. I don't need high performance motors just to get a whoosh pop with my Alpha III. Presumably, sugar motors would be cheaper than BP and APCP motors. What is this gray are that you speak of? Could a legitimate manufacturer certify and distribute low cost sugar motors? It probably would not be Estes, as sugar motors might damage the Estes brand.

I have always liked the Tripoli Experimental rocketry concept, but am disappointed that they prohibit BP motors. It seemed particularly interesting in the bad old ATF days when rocketeers could make and fly motors on the field without having a LEUP and storage. Still, I wanted to see it function more as a small business incubator where people could develop their skills, and showcase their achievements to attract capital and start a proper business. Sadly, I cannot thing of one case where this occurred.

I think the NAR is still firmly opposed to "experimental". They are aware of the problem of a rocketeer wearing two hats, one NAR and one Tripoli. I remember the NAR had a policy that you needed some temporal and/or physical separation as you switched hats. You could not simply take off your NAR hat, move over to the Tripoli pad and fly Tripoli Experimental. Is this NAR policy still in effect?

 

[Steve Shannon]

Could a legitimate manufacturer certify and distribute low cost sugar motors?

I don’t know of any reason why not.

I remember the NAR had a policy that you needed some temporal and/or physical separation as you switched hats. You could not simply take off your NAR hat, move over to the Tripoli pad and fly Tripoli Experimental. Is this NAR policy still in effect?

No

 

[3stoogesrocketry]

Whoa, I'm not trying to skirt around anything whatsoever. I do understand that I can fly the above as a Level 2.

The question, as straight-forward as I can make it -

Can Something Like This - https://www.rocketmotorparts.com/29...Experimental_Motor_Kit/p1577809_15297089.aspx

And Something Like This - https://www.rocketmotorparts.com/29mm_Black_Jack__Propellant_Grain/p1577809_10884768.aspx

Be sold together as an EMK on the open market for use in Tripoli Launches?

Pretend I wanted to have a legitimate business selling EMKs.

Sorry if I phrased that wrong . As stated abaove , no you can not legally as your not the manufacture of the fuel .
YES
YES
NO , unless your open market is RCS

 

[PayLoad]

Now you are just messing with me, right? Right?

"something like this"

If someone came out with parts of their own, parts and fuel grain of their own manufacture, could it be sold together as an EMK on the open market for use in Tripoli Launches?

 

[NateB]

What is this gray are that you speak of?

The gray area as I understand, is due to sugar propellants not being specifically addressed or specifically banned. APCP is no longer regulated, BP has strict regulations for storage, use, and transport with exceptions given for "Toy propellant", consumer fireworks, and antique firearms.

I have always liked the Tripoli Experimental rocketry concept, but am disappointed that they prohibit BP motors. It seemed particularly interesting in the bad old ATF days when rocketeers could make and fly motors on the field without having a LEUP and storage.

Same here. I like larger BP motors and enjoy that I can go to an event like PGI to build and fire them on site. I wish I could do the same at Tripoli launches, but respect that it isn't permitted.

 

[Steve Shannon]

Now you are just messing with me, right? Right?

"something like this"

If someone came out with parts of their own, parts and fuel grain of their own manufacture, could it be sold together as an EMK on the open market for use in Tripoli Launches?

You keep asking the same question. The answer is always going to be the same. If it’s all together in one kit it must be certified in order to be sold.

 

[PayLoad]

You keep asking the same question. The answer is always going to be the same. If it’s all together in one kit it must be certified in order to be sold.

THAT IS AN ANSWER - THANK YOU!!!!!!!!!

 

[3stoogesrocketry]

THAT IS AN ANSWER - THANK YOU!!!!!!!!!

Steve for the win . Thank you for phrasing it properly

 

[jsdemar]

If it’s all together in one kit it must be certified in order to be sold.

And if the motor kit and propellant grains are sold as two line items from the same manufacturer in the same order, the only "research" done was an internet search. The manufacturer has avoided certification and the buyer hasn't learned anything about rocket motors beyond what they would learn assembling a certified reload.
This raises a few questions for the Tripoli BOD that would be awkward to discuss in an open forum.

 

[Steve Shannon]

Steve for the win . Thank you for phrasing it properly

Thanks, but I don’t deserve much credit. if you read Terry’s (@prfesser) first paragraph in post #8, I think it says the same thing.
Where this got confusing was that many of the questions listed two different components: An EMK, and propellant grains. Neither by itself is against the rules as long as DOT rules are followed. If sold simultaneously the intention is suspicious and the optics are terrible. If sold as a single item, intention is clear and no longer legally defensible.
My problem with threads like this became is that it’s like going to the police and asking what where the loopholes are so they can exploit them. Someone’s always trying to see how close to the line they can skate, without any consideration for how it makes the hobby look. What I really want to say is “don’t be stupid!”