A Tootsie Roll of APCP is HAZMAT, But a Pack of APCP Life Savers Is Not. Why?

[jsdemar]

...and often the ones doing the codifying have no idea what they're doing.

That's not the case for the DOT. They've done extensive testing in order to set the criteria for classification. It begins with testing the formulated compound by an independent lab. Then, the packaged device/product is tested to destruction according to specific methods at an independent lab with a DOT representative present. The testing lab makes its recommendation for classification to the DOT who authorize shipping. This whole process isn't cheap.

The quantity of "explosive" or flammable solid, and the separation of the pieces, make a huge difference if something catches on fire. Will it self extinguish without propagating? Will it burn through and propagate to the next item in the box or load? If so, how fast does that happen? Will it cause a mass explosion with projectiles? Or will it detonate with immediate propagation to everything in the box or load?

As John/Bat-Mite said, there has to be a dividing line someone. Unlike the ATFE, the DOT/PHMSA is based on the scientific method and covers a complex range of stuff that ships every day.

 

[Maxwelljets]

Previously, Aerotech and Loki shipped the USPS mailable grains separated in little plastic baggies that were heat sealed with each grain in its own separate section. However, Aerotech's packaging changed within the past few years, and they now ship the USPS mailable grains in the liner, all together, similar to the way CTI motors have always been packaged. Was there a change to DOT/USPS's regulations that allowed this?

 

[boatgeek]

Bottom line, for anyone who wants to skip all of the above -- in summary: Tootsie Roll is no more or less hazardous to ship than Lifesavers. Dumb law, but when you codify things, you have to draw a line somewhere.

The other issue is that if DOT gives exemptions for Estes mailing a big box of motors (separately packaged), they would also need to give exemptions for separately packaged APCP grains. Otherwise, you get into a nightmare of whether the APCP grains are all for the same motor, and whether that I motor is functionally the same as a 25-pack of D12s. I don't have any insight into the relative fire risk of those two types of package, but drawing a regulatory line between them is harder.

 

[UhClem]

No This makes it legal.

USPS packaging regulations require each "device" to be sealed into its "primary receptacle". With multiple primary receptacles in each mail piece. How can you do that by putting multiple grains into the liner. No fig leaf of a plastic bag even.

With each "device" being a 1.4s motor (or equivalent, apparently).

I think that the issue with USPS shipping comes from them relying on proper classification by DOT. Which depends on accurate information from Aerotech/RCS. The DOT information on the Aerotech web site is from 2006 which is before the packaging change. As currently packaged, both the H123 and H130 look UN 1.3C to me.

If DOT decides to add the series 6(d) test requirement to NA0323 like they did to other 1.4s classifications, things will certainly change.

 

[rcktnut]

USPS packaging regulations require each "device" to be sealed into its "primary receptacle". With multiple primary receptacles in each mail piece. How can you do that by putting multiple grains into the liner. No fig leaf of a plastic bag even.

With each "device" being a 1.4s motor (or equivalent, apparently).

I think that the issue with USPS shipping comes from them relying on proper classification by DOT. Which depends on accurate information from Aerotech/RCS. The DOT information on the Aerotech web site is from 2006 which is before the packaging change. As currently packaged, both the H123 and H130 look UN 1.3C to me.

If DOT decides to add the series 6(d) test requirement to NA0323 like they did to other 1.4s classifications, things will certainly change.

Looking back on this thread, different sources/ posts = different numbers. I trust the manufacturers/ vendors know what they are doing to ship the items legally. I personally never looked at the shipping regs. I don't need to, don't ship them. They are very confusing anyway. I don't have any H130's on hand so don't know how many propellant grains there actually are. I know vendors are shipping them USPS.

I do have 3 H123's here and on the instructions the total propellant weight is listed at 121.8g. The Aerotech files on RocSim list them at 125g. The AT motor matrix/ Thrust Curve lists them at 129g. Now it's FAA regs. and more questions, Class 1 motor or not?

 

[Steve Shannon]

Looking back on this thread, different sources/ posts = different numbers. I trust the manufacturers/ vendors know what they are doing to ship the items legally. I personally never looked at the shipping regs. I don't need to, don't ship them. They are very confusing anyway. I don't have any H130's on hand so don't know how many propellant grains there actually are. I know vendors are shipping them USPS.

I do have 3 H123's here and on the instructions the total propellant weight is listed at 121.8g. The Aerotech files on RocSim list them at 125g. The AT motor matrix/ Thrust Curve lists them at 129g. Now it's FAA regs. and more questions, Class 1 motor or not?

Did you include the delay grain when you weighed it?

 

[tbonerocketeer]

Are you positive that it's 1.3 above 62.5g? It was always my understanding that it's 1.4C up to "a few kg" per grain and 1.3C above that. The latter affecting CTI Pro150 and the monolithic 98mm moonburner reloads that have now been replaced with segmented ones (e.g. N1100).

Reinhard

It is, but there is a special permit that allows reclassification as 1.4C if some packaging requirements are met. This is how we ship motors motors 1.4

 

[Reinhard]

For US/DOT, everything above 62.5 grams of propellant (preloaded or per packaged grain) are 1.3 and require hazmat shipping. 1.3C classification is based on packaging and testing for a lower hazard level. 1.4C is for 30->62.5 grams (preloaded or per packaged grain), with the required packaging. Very large grains and preloaded motors are a mass explosion hazard and classified as 1.1.

All of the class groups have a limit per outer package, and per truck/vessel load.

It is, but there is a special permit that allows reclassification as 1.4C if some packaging requirements are met. This is how we ship motors motors 1.4

Thanks for the clarifications. FWIW, I checked the manufacturer SDS and AT indeed lists propellant above 62.5g as 1.3C since 2018 but CTI lists all their reloads except Pro150 as 1.4C as of 2020.

Reinhard

 

[tbonerocketeer]

Thanks for the clarifications. FWIW, I checked the manufacturer SDS and AT indeed lists propellant above 62.5g as 1.3C since 2018 but CTI lists all their reloads except Pro150 as 1.4C as of 2020.

Reinhard

CTI built the special permit into their shipping ex numbers.

 

[rcktnut]

Looking back on this thread, different sources/ posts = different numbers. I trust the manufacturers/ vendors know what they are doing to ship the items legally. I personally never looked at the shipping regs. I don't need to, don't ship them. They are very confusing anyway. I don't have any H130's on hand so don't know how many propellant grains there actually are. I know vendors are shipping them USPS.

I do have 3 H123's here and on the AT instructions the total propellant weight is listed at 121.8g. The Aerotech files on RocSim list them at 125g. The AT motor matrix/ Thrust Curve lists them at 129g. Now it's FAA regs. and more questions, Class 1 motor or not?

Did you include the delay grain when you weighed it?

I didn't weigh any, I will next time I use one, they are sealed up yet. The weights I listed are from the various sources in Red

 

[UhClem]

CTI built the special permit into their shipping ex numbers.

You can't do that.

CTI is in Canada so their explosive classification is through NRCAN, not DOT. The UN system is supposed to produce similar results everywhere, but not always. For example, Canada doesn't have a NA0323 classification since that is strictly a DOT thing for domestic US purposes.

 

[jsdemar]

You can't do that.

CTI is in Canada so their explosive classification is through NRCAN, not DOT. The UN system is supposed to produce similar results everywhere, but not always. For example, Canada doesn't have a NA0323 classification since that is strictly a DOT thing for domestic US purposes.

CTI has many US mil/aero customers and a US address. They deal with the DOT and US testing labs. Search the DOT SP database.

 

[dhbarr]

Call me crazy, but I absolutely trust the people who are putting their business on the line every time they mail my toys to do their compliance homework. The lack of understanding lies with me.

 

[Powderman]

That's not the case for the DOT. They've done extensive testing in order to set the criteria for classification. It begins with testing the formulated compound by an independent lab. Then, the packaged device/product is tested to destruction according to specific methods at an independent lab with a DOT representative present. The testing lab makes its recommendation for classification to the DOT who authorize shipping. This whole process isn't cheap.

The quantity of "explosive" or flammable solid, and the separation of the pieces, make a huge difference if something catches on fire. Will it self extinguish without propagating? Will it burn through and propagate to the next item in the box or load? If so, how fast does that happen? Will it cause a mass explosion with projectiles? Or will it detonate with immediate propagation to everything in the box or load?

As John/Bat-Mite said, there has to be a dividing line someone. Unlike the ATFE, the DOT/PHMSA is based on the scientific method and covers a complex range of stuff that ships every day.

Great response. Manufacturers have to complete a series of(expensive) tests using sand and witness plates to determine what DOT classification their product and packaging combination falls into. If you change your product formulation(outside the range that you submitted with your initial approval to the DOT) or packaging after your testing is completed and approved you have to go back and redo the DOT tests. You can apply for analogies or amendments to your approvals, but you have to have documentation supporting your case. In summary, there are a lot calculations, time and money that goes into you being able to get your motors shipped to you.