Exempt Rocket motors Defined

[rharshberger]

Yeah,but everybody really knows who made the motor. Wink wink.nid nod.

Maybe....not everyone at a launch is in the know, especially large launches.

 

[StreuB1]

Simple

Personal EX = Educational "I am trying to learn"
Commercial EX = I am trying to make money


In a court of law, someone injured or killed by "someone trying to learn" will be more favorably (is there a better term??? lol) viewed, than someone killed or injured by "A company making profits."

I deal with this at work every day in my role. In a court of law "I am stupid, I did not know" and being able to prove you are actually stupid ends up far better than "I knew better and did it anyways."

 

[shockie]

What I am having trouble understanding is why can't uncertified motors from a commercial manufacturer (that were sold for profit) be flown at Tripoli research launches? If insurance and safety was the primary concern then wouldn't Tripoli also NOT want any experimental motors? BALLS has uncertified motors going well into the 'R' range that were mixed in garages and basements. This seems to me like it is FAR more dangerous than if someone contracted Scott from Loki to do the propellant mixing, case machining, etc. where they can have professional input from Scott about their design throughout the whole process.

I don't see the problem with it and the need for a manufacturer to get certified motors when so many uncertified motors are being flown at research launches that were mixed in a kitchen aid seems maybe just a little out of touch if you are worried about safety.
Here is a R motor cato at balls a few years back:

I am completely for individual research btw. Rocketry has been extremely safe EVEN when things have gone bad! Which is why if a university, private company, or even an individual wants to contract Scott, Aerotech, or CTI to make a one-off cocktail, skidmark, or blue thunder P motor, to me seems safer than said university or individual attempting it themselves. Getting a certification on these motors would be pretty pointless since it will probably be sold once. Since I live in California and as we saw in the last thread that mixing in California is sketchy at best and at worst illegal, I would be interested in a service like this. I could make it out to FAR but that is not always easy to do when it is packed with universities and I have to drive 7 hours. A service like this could allow me to design a custom motor in burnsim and CAD (alongside the professional help of any of the manufacturers) then have it shipped out to Black Rock for the launch.

If Tripoli is worried that this will open the floodgates as said above then I think there is definitely some legislation that can limit this. Some ideas off the top of my head are:
1. Must be L2 to purchase uncertified motors
2. Cannot be used to obtain certifications (already in tripoli code)
3. Must be used at EX launches
4. Cannot use the same propellant formulas, geometries, nozzle, etc. to mass manufacture and sell to researchers. Basically prohibits the manufacturer from coming up with a motor that utilizes all of the same parts and formula which would be essentially skipping the cert process
-4b. Each motor must be somewhat designed by the researcher(s) purchasing the propellant but the manufacturer can give professional input to prevent malfunctions

I really don't see how something like this wouldn't be beneficial to researchers and manufacturers. I definitely don't see how this would affect the certified side of the market. In my case, I could see myself purchasing one of these maybe once a year when I decide to make my way 10+ hours out to BALLS. For most of my flying though, Aerotech at Lucerne and Loki research in Vegas!

1. Must be L2 to purchase uncertified motors

You need to be a L2 to purchase uncertified research 1/2A APCP motors? How about restricting it to HPR motors only?

We are talking 2g of propellant folks.

You know, this 1.3.3 exemption language had been there for quite sometime. It was in the 1122 long before it was copied and pasted into 1127.

 

[charrington]

First step in creating a design is to have a well characterized formula that has been static tested and been tested to scale up to your flight motor size. When you say “I want to design a motor and have Scott build it for me” do you mean have Scott use a formula of yours? That would require that you have tested and characterized it and could give Scott the data to then design the motor and possibly need to do more testing depending on the scale up magnitude, ie a formula that has been characterized in 38mm 2 grain test motors probably won’t scale up to a P motor. Or are you trying to design a motor with one of Scott’s formulas like say Loki Red, which would be impossible without Scott giving you the data for it and advising you on the limits of scaling. Designing in ProPep or similar only gets you so far in the theoretical world. I think things could be worked out but you would also have to consider your constituent sources also if this was your tested formula, different AP sources, different metals sources and particle shape, ect ect ect

Great points that I don't fully have the answer to! I do not have any experience outsourcing to a manufacturer as an exempt so I don't know what the process is usually like. I only have experience in mixing a well characterized propellant (MIT Cherry Limeade) when I was at university. I think Scott said in this thread that hes done this work with private entities before but I don't know how they did it. In my completely hypothetical situation for the scale loki dart I would probably opt for designing a prop myself and then have the manufacturer create a few H motors or I motors for propellant testing (paid for by the consumer), Move up to a full scale static test (paid by consumer) and then have another full scale manufactured for launch. This must be done anyway even if I was mixing for myself and in my case I would need to rent out a facility for mixing, purchase all the necessary items for mixing and testing, and then drive hours to FAR spending lots of money on gas and hotel. I think contracting it out would actually save someone in my situation money or be very comparable.

 

[charrington]

1. Must be L2 to purchase uncertified motors

You need to be a L2 to purchase uncertified research 1/2A APCP motors? How about restricting it to HPR motors only?

We are talking 2g of propellant folks.

You know, this 1.3.3 exemption language had been there for quite sometime. It was in the 1122 long before it was copied and pasted into 1127.

In the case of 1/2A APCP motors I dont think there would be a problem getting it certified. Send 2 motors non-hazmat in the mail and then pay the cert fee and boom that motor is now certed. I think the issue arises when talking about motors that cost well over 1k each in materials.

 

[StreuB1]

In the case of 1/2A APCP motors I dont think there would be a problem getting it certified. Send 2 motors non-hazmat in the mail and then pay the cert fee and boom that motor is now certed. I think the issue arises when talking about motors that cost well over 1k each in materials.

There is no HPR motor ever made that costs the manufacturer well over (or even close to) $1k in materials.

 

[Charles Botkin]

I just have to file a DBA as "Lawn Dart Rocketry" and I'm good to go..

 

[sharkbait]

Great points that I don't fully have the answer to! I do not have any experience outsourcing to a manufacturer as an exempt so I don't know what the process is usually like. I only have experience in mixing a well characterized propellant (MIT Cherry Limeade) when I was at university. I think Scott said in this thread that hes done this work with private entities before but I don't know how they did it. In my completely hypothetical situation for the scale loki dart I would probably opt for designing a prop myself and then have the manufacturer create a few H motors or I motors for propellant testing (paid for by the consumer), Move up to a full scale static test (paid by consumer) and then have another full scale manufactured for launch. This must be done anyway even if I was mixing for myself and in my case I would need to rent out a facility for mixing, purchase all the necessary items for mixing and testing, and then drive hours to FAR spending lots of money on gas and hotel. I think contracting it out would actually save someone in my situation money or be very comparable.

Sounds fair enough in your situation.

In the case of 1/2A APCP motors I dont think there would be a problem getting it certified. Send 2 motors non-hazmat in the mail and then pay the cert fee and boom that motor is now certed. I think the issue arises when talking about motors that cost well over 1k each in materials.

you would need to send a minimum of 10 motors depending on type and quantity of delays

 

[charrington]

There is no HPR motor ever made that costs the manufacturer well over (or even close to) $1k in materials.

Im sure aerotechs DMS O motor is somewhere close to that if you calculate in the composite tube, liner, nozzle, and propellant. The cost of Labor is important to factor in too.

 

[charrington]

Sounds fair enough in your situation.

you would need to send a minimum of 10 motors depending on type and quantity of delays

Ah I dont know why I thought it was 2 motors. I thought I read it somewhere earlier but I must be mistaken.

 

[sharkbait]

1. Must be L2 to purchase uncertified motors

You need to be a L2 to purchase uncertified research 1/2A APCP motors? How about restricting it to HPR motors only?

We are talking 2g of propellant folks.

You know, this 1.3.3 exemption language had been there for quite sometime. It was in the 1122 long before it was copied and pasted into 1127.

Keep in mind also that you can still only fly up to your cert level whether EX, certifed, uncertified, exempt, whatever you want to call it. An L2 can only fly up to an M, forget about P’s until you get L3 and then get approval from the TRA class 3 committee and get the FAA waiver approved, unless you have a team together and one can qualify as the flyer of record

 

[sharkbait]

Ah I dont know why I thought it was 2 motors. I thought I read it somewhere earlier but I must be mistaken.

HP over 5,120Ns is only 2

 

[rharshberger]

Keep in mind also that you can still only fly up to your cert level whether EX, certifed, uncertified, exempt, whatever you want to call it. An L2 can only fly up to an M, forget about P’s until you get L3 and then get approval from the TRA class 3 committee and get the FAA waiver approved, unless you have a team together and one can qualify as the flyer of record

Clarification: a L2 can only fly up to a L motor, they may not fly an M.

 

[sharkbait]

Clarification: a L2 can only fly up to a L motor, they may not fly an M.

My bad, big thumb and small cell phone screen, L motor and only commercial M fir cert flight

 

[jsdemar]

As I mentioned in the other thread, if anyone wants official clarification, send a request to the Tripoli BOD. If the request is technical in nature, you may choose to send it to the Tripoli Research committee. If it's only an NFPA change or clarification, follow the process provided by the NFPA.

Some suggested guidelines:

• Be brief and specific.
• Refer to the current safety code and NFPA codes. Make sure you understand the whole context of the codes.
• Understand the limitations of other regulations & laws.
• Consider who would benefit from the proposed exception.
• Consider the risk to TRA, its members, and site owners.
• Does the benefit (to a few) justify the risk (to everyone)?
• Remember that maintaining insurance coverage for launches is the overriding factor which enables our hobby.

 

[jsdemar]

Ah I dont know why I thought it was 2 motors. I thought I read it somewhere earlier but I must be mistaken.

Here's an except from the TMT handbook. If this is only supposed to be accessible by TRA members, please request that the admins remove it.

 

[FredA]

here is no HPR motor ever made that costs the manufacturer well over (or even close to) $1k in materials.

Well, I've made and flown a bunch myself - and I think that's what this thread is about is finding a way to provide for people who, for whatever reason, can't make large/unique motors themselves that can be flown at TRA launches.

I hope we can do that - more P motors = good ;-)
Follow the safety rules and there shouldn't be an issue even if CATO rate goes up, which I doubt.

 

[Steve Shannon]

Yup, I read it wrong. There are 6 types of entity, any of which would need to be "engaged as a licensed business" in motor research (etc). What kind of license do you need to engage in one of those activities? "testing... of... rocket components" sounds like what I do when I build a rocket.

But you’re not in the business of “testing of rocket components.” I am not a lawyer and I’m not your lawyer and I’m certainly not Scott’s lawyer, but being “in the business” is legal terminology which implies that you are actively seeking to earn a livelihood and which federal and state governments occasionally challenge and upon which tax agencies sometimes focus their efforts.

 

[jmasterj]

But you’re not in the business of “testing of rocket components.” I am not a lawyer and I’m not your lawyer and I’m certainly not Scott’s lawyer, but being “in the business” is legal terminology which implies that you are actively seeking to earn a livelihood and which federal and state governments occasionally challenge and upon which tax agencies sometimes focus their efforts.

I am not in that business, correct. "In the business" does not at all imply livelihood, though. I am in the hobby business of selling Lego that I've over-acquired, which requires no license, just reporting income on my taxes at the end of the year (at least in my jurisdiction). All I was trying to say is that being "in the business" might be pretty simple and not require a license nor a ton of work devoted to the business.

 

[Steve Shannon]

Scott claims that NFPA 1127 doesn’t apply to him and thus the prohibition in 1127 against selling non-certified motors should not be applied to his motors.

NFPA 1127 is not the code that applies to manufacturing model or high power rocket motors. NFPA 1125 is. NFPA 1125 is clear in two places:

For model rocket motors:
8.1.3 Model rocket motors, motor-reloading kits, and components offered for sale, exposed for sale, sold, used, or made available to the public shall be examined and tested to determine whether they comply with the standards and requirements detailed in 8.1.7.

For high power motors:
8.2.3 High-power rocket motors, motor-reloading kits, and components offered for sale, exposed for sale, sold, used, or made available to the public shall be examined and tested to determine whether they comply with the standards and requirements detailed in 8.2.7.

Neither of those support the concept of “exempt motors”. Those phrases “examined and tested” refer to certification.

Here are the limited scope exclusions for hobby rocket motors in 1125:

1.1.5 This code shall not apply to the manufacture, transportation, and storage of rocket motors by the United States military or other agencies or political subdivisions of the United States.
1.1.6 This code shall not apply to the assembly of reloadable model or high-power rocket motors by the user.
1.1.7 This code shall not apply to the fabrication of model rocket motors or high-power rocket motors by individuals for their personal use.

The NFPA Rocketry Codes (1122, 1125, and 1127), in in their various versions, have been adopted by many places, both at the state level and municipal level, sometimes in stealth mode, such as part of NFPA 1.

It’s only because NFPA Codes have been adopted by so many government entities that rocketry is not subjected to far more draconian state and local legislation written by lawmakers who have no idea what our hobby is at the behest of AHJs who want as much control as possible . You only have to look at the state of California to see how a state writing its own laws or regulations regarding high power rocketry can make things much more difficult. For that reason Tripoli and the NAR comply with and actively participate in the development of NFPA 1122, 1125, and 1127. But Tripoli is just one entity on the Pyrotechnics Technical Subcommittee and the process of code changes or new code development is very slow and painstakingly deliberate, as it should be.

The concept of exempt motors simply isn’t permitted by NFPA 1125 and for Tripoli to adopt something in direct contradiction to established code could result in something far worse.

You only have to look at the history that Tripoli and the NAR had with Mike Enzi and how his efforts to get legislative relief were shot down by Chuck Schumer to imagine how badly this could go.

I would ask that this whole idea be dropped. It benefits very few while possibly risking the hobby for everyone else.

 

[AlexBruccoleri]

I would ask that this whole idea be dropped. It benefits very few while possibly risking the hobby for everyone else.

I agree. Anyway not to press on legal language, I am still curious on your take on "licensed". Ignoring semantics and people trying to claim their hobby activities are professional. In the case of legit professionals, there is no such thing as a "licensed business" in technology development in many states. Can you clarify or at least give your opinion whether "legally operating" is an adequate substitute.

 

[Steve Shannon]

I agree. Anyway not to press on legal language, I am still curious on your take on "licensed". Ignoring semantics and people trying to claim their hobby activities are professional. In the case of legit professionals, there is no such thing as a "licensed business" in technology development in many states. Can you clarify or at least give your opinion whether "legally operating" is an adequate substitute.

I’m not a lawyer. I think each instance would have to be reviewed by someone with the appropriate business law knowledge. The relevant section of NFPA 1125 is section 5.2.

 

[AlexBruccoleri]

I’m not a lawyer. I think each instance would have to be reviewed by someone with the appropriate business law knowledge. The relevant section of NFPA 1125 is section 5.2.

My question is a little off topic. It is about 1.3.3(2) in NFPA 1127. A hypothetic example for discussion. An legit aerospace company with full time staff wants to test a control system and they build a solid rocket for it. The company is in a state with no "licenses". They are a legit corporation and operating legally though. My understanding is they are exempt from any of the hobby NFPA codes. I am curious on your interpretation.

 

[3stoogesrocketry]

There is no HPR motor ever made that costs the manufacturer well over (or even close to) $1k in materials.

How much do you think it cost CTI to produce a 6 inch O motor ? Do not forget the case counts as a production cost.

 

[Steve Shannon]

My question is a little off topic. It is about 1.3.3(2) in NFPA 1127. A hypothetic example for discussion. An legit aerospace company with full time staff wants to test a control system and they build a solid rocket for it. The company is in a state with no "licenses". They are a legit corporation and operating legally though. My understanding is they are exempt from any of the hobby NFPA codes. I am curious on your interpretation.

I think it’s highly unlikely an aerospace company making rocket motors would escape all licensing (there’s always the feds) and life is too short to speculate about theoretical scenarios.

 

[jsdemar]

In legal terminology, “license” has a general meaning. The authorizing government agency doesn’t have to specifically call it that.

NFPA refers to Merriam-Webster for terms not defined in the codes.

License: “a permission granted by competent authority to engage in a business or occupation or in an activity otherwise unlawful”.

 

[AlexBruccoleri]

In legal terminology, “license” has a general meaning. The authorizing government agency doesn’t have to specifically call it that.

NFPA refers to Merriam-Webster for terms not defined in the codes.

License: “a permission granted by competent authority to engage in a business or occupation or in an activity otherwise unlawful”.

That answers my question, thanks! No need to lawyer the term "licensed". If you are operating legally, your good in other words. Clearly for NFPA, the intent for that exemption is intent to be in a professional business.

 

[StreuB1]

How much do you think it cost CTI to produce a 6 inch O motor ? Do not forget the case counts as a production cost.

TBH, I completely forgot about the CTI 152mm motors.

Though, I would not consider hardware production cost as the reload is what makes it a motor. I could see it both ways though.

I would say though that these are a statistical outlier as these are unlikely to ever be produced again, along with the 130mm motors.

 

[sharkbait]

TBH, I completely forgot about the CTI 152mm motors.

Though, I would not consider hardware production cost as the reload is what makes it a motor. I could see it both ways though.

I would say though that these are a statistical outlier as these are unlikely to ever be produced again, along with the 130mm motors.

Sans case, closure, nozzle, o-rings a 6” O costs me $875.00, I would thing CTI gets a much better deal on materials and chem’s than I do, but then they have to also pay labor costs which would put them over a grand

 

[AlexBruccoleri]

@Steve Shannon , I have a very specific question. can RCS or @Loki Research offer static tests as a service? @charrington and myself are in a similar situation. We live in apartments and homemade motor mixing and testing is out of the question for a lot of reasons including safety. RCS sells a goody bag of components and grains. Assume the static tester has no design input. They simply follow my instructions for the motor.