Motor certification process change proposal

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Jerry Irvine

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There is a thread right now at Rocketry Planet and other places about issues and irregularities with TRA certification methods. It is highlighted by NAR refusing to recognize certifications TRA has extended.

TRA TMT has over the years had many such controversies surrounding their "ethical status".

Suggestion.

Given that motor certification is a long standing and important tradition, users and regulators point to as a key element of wide acceptance of consumer rocketry, it makes sense to do practical and easy things to maintain and improve its credibility.

I think NAR should take over the motor certification aspect from TRA entirely, by mutually agreed treaty, and to the limited extent TRA members have equipment NAR lacks, simply have them volunteer for NAR rather than TRA.

I make this suggestion after trying to improve the credibility of the TRA system both from the inside and from the outside, as a club leader (#007), a member (#012), a vendor (USR), and a volunteer. U.S. Rockets had the very first TRA certified motors. No such improvement in ethics was forthcoming in decades.

I am open to thoughtful replies.

Jerry
 
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I think this has a snowball's chance in hell of happening.

The current RP/ Kosdon / TRA TMT situation could simply have been precluded by requiring Kosdon to provide a copy of his CA state manufacturing/exporter/importer/wholesaler license. And TRA RSO's in CA at TRA Prefecture launches asking to see CA state reseller licenses and local AHJ reseller permits.

The 2008 edition of the CSFM fireworks regulations and laws (yeah that's right in CA MR and HPR are considered fireworks in CA) has been online since 2008.... Frank Kosdon , TRA TMT, TRA BOD and TRA RSO's just decided not to read it or to ignore it.

Nothing new here... they have been doing it, well, since you were illegally manufacturing and selling HPR engines in CA and throughout the USA Jerry.

Terry Dean
 
Since you live in CA, do you have your OSFM permits Jerry?

I'm assuming you aren't dumb enough to start this thread unless you yourself were legal.... Right? Right?
 
Since you live in CA, do you have your OSFM permits Jerry?

I'm assuming you aren't dumb enough to start this thread unless you yourself were legal.... Right? Right?

Permits to do what? The California State Fire Marshal has declared in writing that hybrids are exempt from the rules, and that liquids operated under the direct supervision of a Pyro Op I are permissible.

I don't sell consumer motors in CA and have not since my permit expired in the 90's. Before that I had an agreement with the Fire Marshall's office connected with Lucerne launches since at that time they agreed that while they were pyrotechnics they were not fireworks and both NFPA and ATF exempted them. OSFM was just fine with that until TRA asked them to review their rules. They cheerfully complied.

So, right.

Jerry

cite:
https://v-serv.com/usr/images/CSFM2.jpg
 
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Both NAR S&T and TRA TMT certify commercial hobby rocket motors in compliance with NFPA 1125. https://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=1125&cookie%5Ftest=1

NFPA 1125 requires that commercial hobby motor manufacturers have all required federal, state and local manufacturing permits so it is perfectly acceptable to ask a manufacturer for proof that he has all the required permits.

NFPA 1125 requires that all commercial hobby motor manufacturers have EX numbers for all of their propellants and motors. EX numbers are a DOT transportation requirement for in commerce transportation of hazardous materials, so it it perfectly acceptable to ask a manufacturer for proof that he has the required and current EX numbers. These are readily verifiable on-line at the DOT website.

NAR S&T has attempted to make the hobby rocket certification process as transparent and impartial as possible. We spent thousands of man-hours over the past 5 year to develop and compile a testing policy that is 100% in compliance with NFPA 1125.

Our policies and procedures are listed here. https://www.nar.org/SandT/docs/index.html

Our Motor Testing Manual is downloadable here. https://www.nar.org/SandT/docs/ST-MotorTestingManual.pdf

We maintain on on-line library of downloadable certification documents here. https://www.nar.org/SandT/NARenglist.shtml and an up-to-date compilation of all motors currently certified by NAR, TRA CAR. https://www.nar.org/SandT/pdf/CombinedMotorsByImpulse.pdf

The Republic of California has additional state regulations. The Codes for California Hobby Rocket Motor Manufacturers, Wholesalers, Retailers, and Importers and Exporters are found here. https://osfm.fire.ca.gov/strucfireengineer/pdf/fireworks/FireworksHandbook2008.pdf

It is appropriate for a certifying authority to request copies of the appropriate CSFM licenses, permits and approvals from California Hobby Rocket Motor Manufacturers before any certification testing commences. Certification authorities don't care how business was conducted 2 decades before, they are only concerned with compliance today, in 2010. Past approvals are not relevant.

Bob Krech, TRF Propulsion Moderator
Member, NAR S&T
 
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Both NAR S&T and TRA TMT certify commercial hobby rocket motor in compliance with NFPA 1125. https://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=1125&cookie_test=1

NFPA 1125 requires that commercial hobby motor manufacturers have all required federal, state and local manufacturing permits so it is perfectly acceptable to ask a manufacturer for proof that he has all the required permits.

NFPA 1125 requires that all commercial hobby motor manufacturers have EX numbers for all of their propellants and motors. EX numbers are a DOT transportation requirement for in commerce transportation of hazardous materials, so it it perfectly acceptable to ask a manufacturer for proof that he has the required and current EX numbers. These are readily verifiable on-line at the DOT website.

NAR S&T has attempted to make the hobby rocket certification process as transparent and impartial as possible. We spent thousands of man-hours over the past 5 year to develop and compile a testing policy that is 100% in compliance with NFPA 1125.

Our policies and procedures are listed here. https://www.nar.org/SandT/docs/index.html

Our Motor Testing Manual is downloadable here. https://www.nar.org/SandT/docs/ST-MotorTestingManual.pdf

We maintain on on-line library of downloadable certification documents here. https://www.nar.org/SandT/NARenglist.shtml and an up-to-date compilation of all motors currently certified by NAR, TRA CAR. https://www.nar.org/SandT/pdf/CombinedMotorsByImpulse.pdf

The Republic of California has additional state regulations. The Codes for California Hobby Rocket Motor Manufacturers, Wholesalers, Retailers, and Importers and Exporters are found here. https://osfm.fire.ca.gov/strucfireengineer/pdf/fireworks/FireworksHandbook2008.pdf

It is appropriate for a certifying authority to request copies of the appropriate CSFM licenses, permits and approvals from California Hobby Rocket Motor Manufacturers before any certification testing commences. Certification authorities don't care how business was conducted 2 decades before, they are only concerned with compliance today, in 2010. Past approvals are not relevant.

Bob Krech, TRF Propulsion Moderator
Member, NAR S&T

You seem to be in error TRA is in compliance with 1125 as regards Kosdon. According to the state Fire marshal himself Franklin Kosdon aka Kosdon TRM is not licensed for ANY consumer motors whatsoever.

CSFM office Anthony J. Guevara said:
I am the only one at my agency that reviews and grants any approval of a firework or pyrotechnic item. If any item(s) are approved I send out a wet signature letter verifying the approval, I can assure you that Mr. Kosdon has not received any approval from my agency under my signature as of this date. I have contacted Mr. Kosdon and advised him of his situation as far as being out of compliance with California Law, he has quoted sections of the United States Constitution advising me to the contrary in as far as his need for California license requirements. I have had a California license application sent to his residence and to my knowledge he has not responded.

My advise to you and any other individuals who may be considering purchasing a Kosdon motor be advised that there will now be unannounced inspections at the various venues where the launching of rockets will be conducted, its unfortunate that some individuals within a very respected hobby need to be monitored closer due to non-compliance of the law.

Furthermore the DOT listing show Kosdon has a single 1.3C approval which he has gotten a SP10996 exemption to ship as 1.4C, and ONLY from his home address in Ventura, CA. He has not shown individual article approvals for any reloads above 30g. He has not shown Substance approvals for anything other than ONE formula.

Mr. Holmes of TRA at LDRS-29 stated in a formal announcement that he took reloads from and for Kosdon to (AZ?) for TRA TMT testing.

Paul Holmes said:
From: Paul Holmes [mailto paulholm@xxx]
Sent: Wednesday, June 16, 2010 11:31 AM
To: Tripoli Members Forum
Subject: Re: [TRA] Kosdon J450 Certification Status

To All,

This is official notice Kosdon TRM interim certifications will continue to
be in effect until further notice. Dr. Kosdon has delivered a good part of
the motors for recertification at this time (I picked up a load at LDRS) and
along with three boxes of hardware in my living room, continues to fulfill
our agreement for proactive effort on recertification. We should have a
test date in late July, early August and should have some hard, fast numbers
to present at that time.

Whitney,

Your J450F is good to go for the foreseeable future.

Paul Holmes
Chairman, Tripoli Motor Testing

He did this not only without the required CSFM permits, but without the required DOT permits or packaging. Now since I have no intention of trying to seek a resolution on these matters I will not even raise these comments to the level of an allegation, however bald. I will simply say that the principals themselves have stated this is what happened, and what permits if any that were required are up to the respective agencies to parse. I for one wish for gross lenience.

However the point I raised initially was ethics. Had these same motors been submitted to NAR S&T, they would have asked they be shipped to the test point or person, properly packaged, by whatever carrier or person might be legal.

If I ever venture into the shark infested waters of consumer motors again, that's what I will do and I will probably make sure there is HD video of it happening to assure everybody knows it happened exactly as reported.

I noted in my LDRS article how Kosdon did it. Holmes noted in his TRA listserve post how he did it.

As is sometimes said in other venues, "I report, you decide".

In any case my solution is not attacks and enforcements and dime droppage as is the Kosdon mantra, but to suggest the more respected of the two clubs take over the function by mutually agreed treaty.

It is a political solution to a sticky political problem with actual enforcement reprocussions pending as we speak. That will happen entirely independently of this internet chat.

Just Jerry

cite:
https://www.rocketryplanet.com/forums/showthread.php?t=6693&page=30
 
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Thank you for the evidence against Chris Pearson, Frank Kosdon, Charles Rogers and of course yourself. But will you please stop stalking me? Your posts have nothing whatsoever to do with the current subject, unless you realize SNOAR News is perhaps the most biased source ever, and they have shaded the story to make Frank the hero when we now know he is the zero, and always has been.

I suspect the 1.3C approval he has, is a nearly precise copy of the formula SEALED under Ventura civil case 117435. Wanna bet?

The victor writes the history, but the survivors write the biographies and the counter-propaganda.

I point you to the San Diego club newsletter of the 1-1990 trip of Frank and myself to Ocotilllo, CA where the "U.S. Rockets Reloadable" is demonstrated by "Franklin Kosdon". The article was "reprinted" in TRA's magazine with a few details slightly modified. Check that. You claim to be a historian. BTW the PUBLISHER of the San Diego newsletter TESTIFIED in court in 117435 as to the facts I just stated.

Notably the PUBLIC, PUBLISHED demonstration of a U.S. ROCKETS consumer reloadable with delay preceeds the two patent filings, one by Chuck Mund of the design he "got" from me, and the one Rosenfield filed which he "got" from Scott Dixon.

I have posted a bunch of counter-details to the many things said in an OHIO based SNOAR News by a guy who ADMITS to be on a jihad against me. He might be slightly biased and inaccurate. Perhaps not the best source for a "historian".

The accurate version of history is interesting if only because it reads like an episode of Enron on steroids. I have done the very best I could to post as many details as practical to a worldwide, public, uncensored, searchable, archive called usenet rec.models.rockets.

Jerry

cite:

View attachment Rocketry Planet.pdf

RPresponse.jpg
 
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Why do these discussions ALWAYS turn this way. I mean I really am for freedom to say what you want. but this was a question about NAR and TRA and maybe only having one testing motors.. Not to flame ANYONE about stuff that happened in the past, or to ask about what people did at LDRS.. or anywhere else. you want to flame that start another thread.

Back to the topic. Jerry I don't EVER see that happening. Both entities are WAY to (for lack of better words) Selfish or maybe egotistic to get along that well. and who knows who has who in who's back pocket. Those arrangements could never work if they "merged" that is if there is anyone in anyone's back pocket.. But I am just saying. (come on laugh its a poke in fun)
 
Back to the topic. Jerry I don't EVER see that happening. Both entities are WAY to (for lack of better words) Selfish or maybe egotistic to get along that well. and who knows who has who in who's back pocket. Those arrangements could never work if they "merged" that is if there is anyone in anyone's back pocket.. But I am just saying. (come on laugh its a poke in fun)

Nobody knows better than I the politics of NAR and TRA. TRA is about to get spanked over Kosdon.

I am suggesting they have had treaties in the past. When TRA tried to TAKE OVER the NAR the outcome of that was a treaty to not interfere in each other's business and boards. That treaty still exists today and explains why NAR quietly did not adopt the Kosdon extensions without any comment or blast-back against TRA.

It explains why the TRF Propulsion Moderator and S&T weenie does not criticize TRA or even agree with obvious pending issues. He wears too many hats for someone with top-level media access. You are forgiven Bob, but I am allowed to have a bit of fun at your expense.

There are a couple of other treaties. The cross-certification agreement, and others. They are all appropriately secret and only discussed in executive session of the respective boards. This is not a scandal.

They could very easily enter into an agreement whereby NAR is the designated "point man" for all certification approvals, until this soon-to be harsh episode blows over for TRA. It might take a couple of years.

TRA should not take this lightly. They should get in front of this and become the most ethical and transparent thing the world has ever seen for 2 years. They should be so squeaky-clean even *I* endorse them, member or not.

Jerry
 
True (at least considering what I know of) But saying it SHOULD happen does not mean it WILL happen. :cheers:
 
Interesting subject, but I don't see it happening..AND I am glad to see, that for the most part, we can agree to disagree without being disagreeable! :)

BTW, welcome to TRF Jerry! ;)
 
I am suggesting they have had treaties in the past. When TRA tried to TAKE OVER the NAR the outcome of that was a treaty to not interfere in each other's business and boards. That treaty still exists today and explains why NAR quietly did not adopt the Kosdon extensions without any comment or blast-back against TRA.

The NAR's position was announced and published. You can read it here.

I disagree with your idea to have one testing organization. Knowing that the manufacturers have a choice keeps us on our toes.

I agree that Bob is an S & T weenie but not that TRF is "top-level media access".
 
I agree that Bob is an S & T weenie but not that TRF is "top-level media access".

:D

Hi Bill. I am an old fart weenie.

TRA might get so far as to discuss liquidation and I suspect they will select NAR over RRS/RRI/AMA.

Jerry
 
Don't engage in this troll thread. If you do, you will be frustrated with the insane logic displayed by the troll author, angry that you let yourself get sucked into the troll, and come to believe TRA, NAR, NFPA are all as evil as the BATFE and CPCS.

Been there done this many times. It's not worth the energy.
 
You seem to be in error TRA is in compliance with 1125 as regards Kosdon. According to the state Fire marshal himself Franklin Kosdon aka Kosdon TRM is not licensed for ANY consumer motors whatsoever.

Please reread what I wrote.

Furthermore the DOT listing show Kosdon has a single 1.3C approval which he has gotten a SP10996 exemption to ship as 1.4C, and ONLY from his home address in Ventura, CA. He has not shown individual article approvals for any reloads above 30g. He has not shown Substance approvals for anything other than ONE formula.

Mr. Holmes of TRA at LDRS-29 stated in a formal announcement that he took reloads from and for Kosdon to (AZ?) for TRA TMT testing.

DOT-SP 10996 permits are issued to individuals or businesses for "in commerce" transportation. Provided that the person using the permit is trained in Hazmat shipping, the permit can be used by the individual from any location.

Transportation by an individual is not "in commerce" transportation so DOT is not involved unless the quantities transported are extremely high.

He did this not only without the required CSFM permits, but without the required DOT permits or packaging. Now since I have no intention of trying to seek a resolution on these matters I will not even raise these comments to the level of an allegation, however bald. I will simply say that the principals themselves have stated this is what happened, and what permits if any that were required are up to the respective agencies to parse. I for one wish for gross lenience.

However the point I raised initially was ethics. Had these same motors been submitted to NAR S&T, they would have asked they be shipped to the test point or person, properly packaged, by whatever carrier or person might be legal.

If I ever venture into the shark infested waters of consumer motors again, that's what I will do and I will probably make sure there is HD video of it happening to assure everybody knows it happened exactly as reported.

I noted in my LDRS article how Kosdon did it. Holmes noted in his TRA listserve post how he did it.

As is sometimes said in other venues, "I report, you decide".

In any case my solution is not attacks and enforcements and dime droppage as is the Kosdon mantra, but to suggest the more respected of the two clubs take over the function by mutually agreed treaty.

It is a political solution to a sticky political problem with actual enforcement reprocussions pending as we speak. That will happen entirely independently of this internet chat.

Jerry

There are roughly 6,000 hobbyists in the US who care enough about hobby rocketry to be members of a National rocketry organization: NAR, TMT or both. (In round numbers, NAR membership is ~5,000, TRA ~3,000 and ~40% of NAR members belong to TRA.)

There isn't a great difference between the two organizations, but if I were to broadly generalize any distinctions, IMO NAR emphasizes skills and TRA emphasizes thrills. NAR has a strong model rocket program aimed at bringing youth into the hobby through skill development programs such as NARTREK, TARC and NAR Level A and B competitions. TRA emphasizes high power rocketry for adults, and amateur rocketry labeled as Research. Both organizations have a role in keeping rocketry viable as a hobby, and fully 1/3 of the serious hobbyists belong to both organizations.

The only way our hobby can survive is to have safe commercial rocket motors readily accessible to the public without undo restrictions. To insure a constant supply of safe commercial hobby rocket motors, NAR instituted S&T and TRA instituted TMT. Our hobby rocket motor certifications for performance and safety are accepted by, and meet governmental and insurance industry standards. This permits rocketry enthusiasts to have a constant supply of safe commercial rocket motors available at affordable prices.

S&T is chartered by the NAR by-laws and reports to NAR BOT, and ultimately to the NAR President. TMT is chartered by the TRA by-laws and reports to TRA BOD and ultimately to the TRA President. Both organizations are recognized by NFPA and the civil AHJ as experts in the field and perform hobby rocket motor certifications as specified in sections 7 and 8 of NFPA 1125, motor testing. In the simplest of terms, the role of S&T and TMT are to affirm that the labeling and markings on a small sample of motor submitted for certification testing are accurate, and that the instructions provided with the motors give sufficient information for safe operation.

All other aspects of compliance to NFPA 1125 is the legal responsibility of the commercial motor manufacturer, not the volunteer certifying group. The manufacturer is legally responsible to meet all local, state and federal business requirements, and to perform routine QC testing of their products so that they perform in the same manner as the motors they submitted for certification.

Certifying groups are not policemen or law enforcers. We require that a motor manufacturer affirm that they are in compliance with all the other aspects of 1125, however we lack the legal authority to inspect facilities, or the financial resources to perform detailed business investigations. If we obtain contradictory information, we investigate it within our abilities. If we fall short, the organization presidents have the ultimate authority to correct any oversights that may have been made.

Making wild speculations, accusations, and inflammatory remarks here won't resolve anything. If you have a problem with certification testing, please take the fight outside, and address your concerns directly to Trip Barber, President of NAR and Terry McCreary, President of TRA.

If you have questions concerning the legality of any hobby rocketry enterprises, please refer them to the appropriate AHJ. I'm sure they'll listen to you.

Bob
 
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DOT-SP 10966 permits are issued to individuals or businesses for "in commerce" transportation. Provided that the person using the permit is trained in Hazmat shipping, the permit can be used by the individual from any location.

Bob

Correct. The reclassification exemption may be used to ship from anywhere for materials originating at the stated address in the underlying 1.3C approval. In this case, Ventura, CA. The issue being that address or vendor has never received any state consumer manufacturing approvals or individual item approvals as many other vendors do have, even from out of state.

That said and taking the majority of what you said as given, my concern is TRA in particular, says they are not enforcers but then engage in arbitrary acts of enforcement. Decertifications, refusals to certify, largely based on claims of a lack of some paperwork, as well as serial extensions and TRA-Kosdon agreements based on unfilled promises of future compliance and testing.

In my case when I had in-place certified motors, TRA asked for a BATF permit even though BATF themselves agreed it was not required and no materials at issue were ever required to be logged in under my permit. I tendered the permit to TRA solely at their request and they STILL decertified the motors. So I have concerns about the details of how the policies are enforced.

I also have reason to believe there has been some change of personalities at TRA to indicate this issue may be less arbitrary for me, but then I observe it is clearly is still arbitrary for Kosdon.

This concerns me. This concerns the industry.

Here is SPECIFICALLY why:

Anthony J. Guevara said:
My advise to you and any other individuals who may be considering purchasing a Kosdon motor be advised that there will now be unannounced inspections at the various venues where the launching of rockets will be conducted, its unfortunate that some individuals within a very respected hobby need to be monitored closer due to non-compliance of the law. Any person found to be in possession of any unapproved motor will be cited and their motors seized.

And no I am not trolling and broadband accusing TRA/NAR/NFPA of massive corruption. I am bringing narrow, specific, concerns to attention in about the only venue I can, in the most civil and factual way I can muster.

Can't we find a way to resolve this "in the family" without involving the AHJ's and authorities any more than absolutely necessary? They might appreciate that.

Jerry

"very respected hobby" - Anthony J. Guevara
 
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Don't engage in this troll thread. If you do, you will be frustrated with the insane logic displayed by the troll author, angry that you let yourself get sucked into the troll, and come to believe TRA, NAR, NFPA are all as evil as the BATFE and CPCS.

Been there done this many times. It's not worth the energy.


[snipped by DAllen - not worth the effort or the flames]
 
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DOT-SP 10996 only allows for the reclassification of a Class 1.3 material to a Class 1.4 material. It has nothing to do with the generic Limited Quantity Exemption which specifically excludes Class 1 Materials.

https://www.phmsa.dot.gov/staticfiles/PHMSA/SPA_App/OfferDocuments/SP10996_2007090226.pdf

If your name is not listed as a signatory to the Special Permit on the attached list, you can't play.

Each container also must be labeled as

UN0351, Articles, explosive, n.o.s.(rocket motors or reloadable rocket motor kits, as appropriate), 1.4C, II, NEW xxx pounds, GW yyy pounds

and all propellants and articles in the package must have approved EX numbers.

I really hope Frank has all the necessary DOT documentation, paperwork and permits in place before he uses his DOT Special Permit to place his rocket motors in commerce. The penalty for intentional non-compliance is severe and in the past fines of $40,000 have been levied for improperly shipping rocket motors. That's a painfully large amount of cash to loose for not playing by the rules.

Bob


View attachment Signatories to SP 10996 as of 5 July 2010.pdf
 
It is appropriate for a certifying authority to request copies of the appropriate CSFM licenses, permits and approvals from California Hobby Rocket Motor Manufacturers before any certification testing commences. Certification authorities don't care how business was conducted 2 decades before, they are only concerned with compliance today, in 2010. Past approvals are not relevant.
It is very nice to see your position in black and white.

Thank you, Bob.
 
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It is very nice to see the NAR S&T position in black and white.

Thank you, Bob.
Darrell.

I'm simply the tech guy at S&T. I don't set policy. My comments are my interpretation of what the policy is, but do not necessarily represent the official policy of S&T or NAR.

I spent a year and a half several years ago compiling all existing S&T testing procedures into a single document, and getting it on the NAR website. I had a lot of help in the process from the other members of S&T, the S&T admin group, and the NAR executive officers. I think the end product is pretty good, but not perfect, as it can't possibly cover all possibilities. All S&T policies have to be approved by the Chairman, and ultimately the NAR President.

Bob
 
Understood, Bob. I edited my response to correctly show that this was your position and not an official organizational position. Still, the fact that you reached it, and published it, is important to me because it means there are others that must have similar points of view, i.e. you didn't get there in a vacuum.

It benefits no one in the long run if an organization turns a blind eye to "intentional non-compliance" as you called it — I agree. Andf it also benefits no one when that blind eye is converted into a condoning nod and a wink with improperly administered certifications. It's a shame your position isn't shared in other organizations' testing groups.
 
Bob, while I agree with your "personal opnion" why can't we get the same position officially from the NAR as a policy?

So will you quit your tech job at NAR if their policy is different from your personal policy?

I mean why isn't it as simple for both the NAR and the TRA to say : we will not accept for certification, any motors, from any California manufacturers, without them first providing their CSFM manufacturing license?

Why don't you personally suggest this policy change to the NAR S&T, the NAR BOT and the NAR President? You don't think Trip would go for this?

Both org's have had the opportunity to make this simple change in policy for over 25 years , and neither have.

Terry Dean
 
Bob, while I agree with your "personal opnion" why can't we get the same position officially from the NAR as a policy?

So will you quit your tech job at NAR if their policy is different from your personal policy?

I mean why isn't it as simple for both the NAR and the TRA to say : we will not accept for certification, any motors, from any California manufacturers, without them first providing their CSFM manufacturing license?

Why don't you personally suggest this policy change to the NAR S&T, the NAR BOT and the NAR President? You don't think Trip would go for this?

Both org's have had the opportunity to make this simple change in policy for over 25 years , and neither have.

Terry Dean

Terry, I generally find you to miss important details and to be an alarmist and as a historian I appreciate the details you get right, but . . .

In this case and this is from someone never at a loss to criticize a motor certification authority, but NAR does check that.

Sorry to pop your bubble, but then you can always buy a "Dude" on ebay.

Jerry
 
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Bob, while I agree with your "personal opinion" why can't we get the same position officially from the NAR as a policy?

So will you quit your tech job at NAR if their policy is different from your personal policy?

I mean why isn't it as simple for both the NAR and the TRA to say : we will not accept for certification, any motors, from any California manufacturers, without them first providing their CSFM manufacturing license?

Why don't you personally suggest this policy change to the NAR S&T, the NAR BOT and the NAR President? You don't think Trip would go for this?

Both org's have had the opportunity to make this simple change in policy for over 25 years , and neither have.

Terry Dean
Terry

Everyone in NAR is a volunteer. No one gets paid. We all have real jobs and we all have a life outside the hobby. There are only 24 hours in a day.

S&T and TRA are not policemen nor do we want to be. We have no law enforcement authority nor do we want it. There has to be some basic belief that folks in the hobby are honest. We require a motor manufacturer to affirm in writing that they are in compliance with all aspects of 1125, however we lack the financial resources and legal authority to inspect facilities, or the time and financial resources to perform detailed business investigations. If we obtain contradictory information, we will investigate it within our abilities.

I don't have a job at NAR. I volunteer my time. How many times have you disagree with someone at work? and quit? You must have had a whole lot of jobs. LOL

Bob
 
S&T and TRA are not policemen nor do we want to be. We have no law enforcement authority nor do we want it.
The California OSFM are not policemen, either. They simply collect the money and issue the paperwork. California's law enforcement authority is the state's attorney. Why can't the motor testing groups ask for copies of the paperwork and note whether it is submitted or not?

There has to be some basic belief that folks in the hobby are honest.
I believe that basic belief system is in place and is being abused, otherwise we wouldn't be talking about this.

We require a motor manufacturer to affirm in writing that they are in compliance with all aspects of 1125, however we lack the financial resources and legal authority to inspect facilities, or the time and financial resources to perform detailed business investigations.
So how do they do that? Do they sign an affidavit stating they are legal or do they submit copies of their paper work?

When you file for specialized homestead exemptions, in this case in my state for those 65 years or older seeking additional exemptions, you submit copies of the prior year's tax return. If they can't look at the return to verify what you were claiming as your prior year's income, you don't get the additional exemption. Asking to see the required paperwork doesn't require enforcement action, or additional resources. It's simply a verification layer.

The same system could work with testing motors. In fact doing so should reserve finite resources by allowing you to not waste time certifying motors for those who are not playing by the rules.

If we obtain contradictory information, we will investigate it within our abilities.
Ok.

What if you hear that a given manufacturer is not legal and he submits his motors for certification. Will NAR turn him away?

What if another organization certifies his motors and you've heard he isn't legal. Will NAR refuse the reciprocal certification?

Thanks.
 
Heard he is not legal from the mouth of the (state) authority himself, personally.

Let's at least take out hearsay for the purpose of this discussion.

Jerry
 
Bob, I'll ask the question again:

why isn't it as simple for both the NAR and the TRA to say : we will not accept for certification, any motors, from any California manufacturers, without them first providing their CSFM manufacturing license?

This doesn't cost any money to ask for this piece of paper; it doesn't require you to act as the police; it doesn't cost any money to verify it other than a simple phone call or email to CSFM.




Terry Dean
 
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