Can you build J and higher motors at home without having a Level 1 Certification?

[Loki Research]

I bring up one of these rules, 10-6 of the Unified Safety Code, try to discuss the rule with the rule makers and what happens? Both those who could potentially benefit from the removal of the rule and proxies of the rule makers scream out of reflex, DON"T ROCK THE BOAT!!! That means they want everyone else to pick the safe side which is silence, complete silence, lest the rule maker and their proxies point their fingers at YOU! Don't be bullied by the bullies. Speak up with your thoughts, whatever they may be. These are YOUR clubs. The sooner you believe that and act on it, the sooner you and your club will benefit from it.

I'm not trying to silence anyone.
Are you?
Are they?

Loki Research = My wife and I.

University sales of non-certified custom motors could be a boom for our business, IF they were allowed to be flown without the impediment of the TRA's own rules. THEY KNOW THIS.

Not all testing requires thrust and pressure measurements. Thermal tests for liner and nozzle thickness requirements just need to be hot fired. I'd rather sell a hot-fire motor to and exempt entity needing that motor, and do so at a business boosting profit, rather than having to eat the entire cost myself. It's likely I would never conduct a 98mm test like this, let alone the number required to answer the thermal test questions because any potential profits would be too far away down the road, and I wouldn't have been able to afford the required materials needed to preform such tests. My past University sales from one school only will soon result in 98mm reloadable Loki motor hardware with a few reloads being available to everyone. Without those sales, I wouldn't have any 98mm motors to offer next year or the year after that, or the year after that, because the process has taken that long and I'm still working on it.

 

[jsdemar]

.... (/tldr again) ....

Scott, I still see no purpose for you to be venting here, other than for potential customers to see you as a petty whiner and run away.

Prefects and clubs are allowed to have more strict additional rules outside of the Tripoli Safety code and beyond the limits of the local AHJs. Respect that or go somewhere else. Simple.

TRF isn't the place to get the answers and clarifications you're looking for. Present a very specific, well thought out question to the TRA BOD in writing directly. No whining about the past, just look forward. Beyond that, pay an attorney to research the laws and regulations your business needs to follow in order to do what you'd like to do.

No need to reply here.

 

[rfjustin]

A "licensed business" is a general term which depends on the type of business and its location. This includes permits from Federal, State, and local jurisdiction to operate a business, manufacture, store intermediates, etc., plus tax registrations. It's up to the individual proprietor or the corporate officers to search out what's required.

Businesses selling rocket motors to other businesses, universities, government entities, etc. is not within the scope of NFPA 1125/1127, or more specifically, these transaction are not within the state/local jurisdiction which have adopted NFPA 1125/1127 within their codes and regulations. There's no single clearing house for this information. A business should not expect TRA officers, volunteers, prefects, or this forum's members to advise them on their business decisions, IMO.

What Scott is missing is this: TRA has the right to set policies for members, prefectures, and launches. This is coupled to its ability to insure launch activities. Launching a rocket with an uncertified motor sold by a business to another business (or college) is outside the definition of a rocket motor that is allowed at an insured TRA launch. Tripoli specifically allows only certified commercial motors and motors made by individual within the limits of Research Motors defined in the TRA Safety Code. "Not for profit" is one of the limitation of Research Motors allowed at TRA launches.

Bottom line, I think, is this: a rocket motor manufacturer can do whatever they want, but don't expect Tripoli to insure motors at launches that were made outside of the Tripoli Safety Code and TRA policies.

I earn my living in risk mitigation, and I approve this message.

 

[StreuB1]

I earn my living in risk mitigation, and I approve this message.

Part of my job is the same (I get to be the liaison for UL and also am the Manufacturers Technical Representative; YAY!). I also approve of this message.

the past, just look forward.

I cannot agree with this enough.

If people didn't care, we wouldn't say this. John cares, I care, Justin cares, lots of others care. Eyes forward, fcuk the past.

 

[AlexBruccoleri]

I bring up one of these rules, 10-6 of the Unified Safety Code, try to discuss the rule with the rule makers and what happens? Both those who could potentially benefit from the removal of the rule and proxies of the rule makers scream out of reflex, DON"T ROCK THE BOAT!!! That means they want everyone else to pick the safe side which is silence, complete silence, lest the rule maker and their proxies point their fingers at YOU! Don't be bullied by the bullies. Speak up with your thoughts, whatever they may be. These are YOUR clubs. The sooner you believe that and act on it, the sooner you and your club will benefit from it.

When I mentioned not rocking the boat, I was referring to the NFPA codes. Those codes are well established in many formal fire codes and making any changes seems unwise unless there is clear and overwhelming support to make such changes, IMO. TRA and NAR rules are different. Those clubs can work with their insurance company to change their rules more easily than NFPA. I mostly agree with @jsdemar except I think you should first work with @AeroTech and maybe CTI as well to gain their support. Once you have a consensus as a group of motor manufacturers, I suspect the TRA BOD will be willing to have a reasonable conversation about any rules changes you collectively propose.

 

[Loki Research]

John, I'm not missing anything at all.
Yes, the TRA has the right to make their own code, I never said they didn't. They equally have the right to change things in their code so that they might help keep around the very last small business making hobby rocket motors keeping AT from having a complete monopoly in the US. As it would seem, the policies and codes the TRA has been enacting are if anything designed to drive me away or out of business and prevent anyone else small from ever entering the market of hobby rocket motors. It's just not worth it. I do not have the support of any TRA board member that I am aware of. If they do support me, they have been silent about it. I would be foolish to believe I can get the current board to do anything at all on my behalf without the support of a large number of club members backing my position. THAT, is why I am here John, not for you to hear me whine. I have brought "selling non-certified motors to 1127 exempt entities and insuring the flights" to Steve and he has shut me down. He insists I must bring Gary aboard to get anything done.

Is this what the members that I'm "whining to" here want, for me to go away and disappear? I seriously doubt it. I'd bet your last yearly NASA funded salary they would rather have 5 more companies just like Loki Research rather than to see me be banished by the TRA and disappear, never to be seen again. Right now, the TRA has that power and they have people in charge that will use it. My "wining" is to lay out some of the actions these people have taken to get to the point that fliers have 1 motor manf in the US left to choose from. If I go away, at least the fliers will know why.

I'm not whining, but pissed off, frustrated, and completely fed up with being bullied around and pushed aside and ignored. I'm trying to type that out in such a way that the mods don't get their wish. I'm tired of the hypocrisy and double standard for rules which we are ALL suppose to abide by in order to be respected members of this club and keep our membership. Join up today! Be a TRA member and follow all our rules, if you want. Have your own club insurance? Then you can be a TRA member who flies rockets at night without an FAA waiver and the national club WILL NOT CARE to do ANYTHING to you if your connected business is big enough. Leave it in the past they say. To ignore the past is to be blind and ignorant of how we arrive at the present. If you want to change course, it is best to know how you arrived at your present position.

Gary just told us all how he's been helping/advising to write the NFPA codes for 40 years. He helped to write the codes that have constricted the market he now controls and he sits on the TRA Board of Directors. Think about that. How many businesses does NFPA 1125 cover in the US? One? What was the need for 1125 then and now? To keep manfs safe or to make it so difficult to comply with the code, that only a major player would ever dare even try.......

One day not to far back, EX motors were not flown at TRA launches. The reason then was that the TRA codes would not allow it, and even if they DID allow it, EX motors could not be insured. Now today, they are insured. Presto! So what changed? The rules that were wrote by the club.

Insurance it always the scapegoat. I find it extremely difficult to believe that a flier with a L2 or higher can now launch their boomstick completely safe and insured but a non-certified motor from a licensed manufacturer in business for 15 + years making rocket motors is somehow less safe and not insurable at all? B.S.
Justin.... your 2 cents here please.

 

[Loki Research]

Brian, or anyone else. You've been hypothetically punched in the face once a year for the past 10 years by a group of people you have no choice but to interact with. Now, go work with and deal with these same people who punched you in the face for 10 years and just move on from the past. Don't bring up the punches they have hit you with in discussions with others who's help you need to influence their actions, just keep quiet about the punches and the crap they have thrown at you for 10 years and just move on. Easy right? Then when they say NO to you, the others ignorant of the past just say well that was weird.... and have no clue.

Could you seriously do that without keeping your guard up 110% and warning others around you? No, you'd be a fool not to.

I'll say it again, to ignore the past is to be blind and ignorant of how you arrive at the present. If you want to change course, it is best to know how you arrived at your present position by reviewing the past course of action. Who here would dissagree with that?

 

[Loki Research]

I feel like an abused house wife being told to keep quiet and not bring up the past because hubby has a new job at the women's YMCA.

I should keep quiet, shut my mouth and not warn anyone else of my husbands abuse and hope for the best that he won't hurt anyone the same way at the Y.

 

[StreuB1]

You'll never hear me say or to encourage anyone to forget the past.

You will hear me encourage people to face forward, do not forget the past, do not let the past control your forward momentum.

At my company, where I am going on 19 years there. Was abused for a decade. Over time, good won over evil. I am now, arguably[by myself], one of the most influential people in my entire global company, across 4 countries......and I am not even a manager. I kept my eyes forward, and did not let the wrongs (terrible terrible wrongs) of my past with the company, control my belief in the future. It assured that I was prepared for any ill will directed towards me, but overall, good does win out. Whatever good is irrespective to whatever situation. And even if it doesn't, focusing on you is the single greatest thing to assure a positive outcome, for you.

 

[jsdemar]

Scott,
In one or two sentences, what do you want to be changed to help you make more money? If you can be clear and concise, more people might be willing to help you. No history, no "woe is me", no blame game... just the specific code and what should be changed. No explanation, no commentary, since it's all contained in your previous messages.

 

[jderimig]

A hypothetical (but very close to a real world case I am involved in).
Can a university team design and fabricate parts of a motor (case, nozzles, closure), ask Loki to supply a grain geometry and propellant formulation to meet a ballistic requirement defined by the team, furnish the grains and fly them at a TRA launch and be covered by Tripoli insurance?

Edit: Can an incorporated rocket club(Fed EIN number, state corporation filing etc) do the same?

 

[AlexBruccoleri]

@Loki Research I second what @jsdemar said. I also would like you to write a follow on post, as detailed as you like, answering why selling custom motors is better for your business, rather expanding the supply of your already certified motors? I am confused why you are not aggressively trying to expand your inventory and dealer network. It is clearly your business and you know it the best, but you are here on the TRF and we are trying to help with advice.

Yes, oddly enough, I want a custom motor, but I am confused why you would even bother helping me with it. Given you already have a wonderful selection of motors, this is very bizarre.

Also from a "good of the hobby" perspective, it would benefit everyone if you boosted the inventory and availability of your current selection. You claim there is threat of a US monopoly if you go away. @AeroTech clearly has little to no desire to do low volume work, and if anything, they are cutting back their own inventory since it is not cost effective for them to make a handful of motors. If you shifted your attention to custom work, wouldn't that in effect give @AeroTech a monopoly? In a previous post they signaled a lack of support for selling ex motors for profit, essentially encouraging you to stay in the certified market. In other words, Gary is not looking to shut you down or avoid competing with you. Business competition is not a zero-sum game and you being successful could make @AeroTech more successful too.

I get answering my question could reveal confidential information and if you would rather not respond that is okay. That being said, you are asking for rule changes that irk a lot of people so a detailed explanation seems reasonable.

Ok and lastly @jderimig asked the same thing I was thinking. One work around would be to offer more ex components and propellant grains. RCS sells a whole selection of ex goodies. Your site offers some too, but you should consider expanding it as far as TRA rules allow.

 

[sharkbait]

A hypothetical (but very close to a real world case I am involved in).
Can a university team design and fabricate parts of a motor (case, nozzles, closure), ask Loki to supply a grain geometry and propellant formulation to meet a ballistic requirement defined by the team, furnish the grains and fly them at a TRA launch and be covered by Tripoli insurance?

Edit: Can an incorporated rocket club(Fed EIN number, state corporation filing etc) do the same?

Maybe off base here with your specific intentions and/or goals of your university team but our club mentors a university for SLI and it’s full commercial motors only. We also mentor a university for ESRA IREC and it would not fit the (COTS) category for sure and would seem at the very least to be unfair in the (SRAD) category.

 

[StreuB1]

A hypothetical (but very close to a real world case I am involved in).
Can a university team design and fabricate parts of a motor (case, nozzles, closure), ask Loki to supply a grain geometry and propellant formulation to meet a ballistic requirement defined by the team, furnish the grains and fly them at a TRA launch and be covered by Tripoli insurance?

Edit: Can an incorporated rocket club(Fed EIN number, state corporation filing etc) do the same?

It would almost entirely depend on how the "University Team" was OFFICIALLY structured.

Many "Teams" get around this by flying under a flyer of record. Its nothing new, that's how I flew M's when I was 14.

I am not keen on the 'hiding' behind a flyer of record, personally. QCRC supports an enormous number of University students every season to get their L1/L2 certs to try and get them to actually BE INVOLVED and learn and not just jump in and buy 'N5800's.' Though, there is nothing legally stopping them from buying N5800's (or whatever the largest motor they can get their hands on, which is what they all want to do) as they are a university. The thing that stops them is the ability to actually fly them, which Tripoli is the supporting organization that allows them a venue to fly said N5800's. Though, we all strongly discourage that and we all try and foster an environment of learning, getting your feet wet, being involved and not just jumping in with your universities deep pockets and blowing $20k in propellant in a semester because it "looks cool."

 

[StreuB1]

Maybe off base here with your specific intentions and/or goals of your university team but our club mentors a university for SLI and it’s full commercial motors only. We also mentor a university for ESRA IREC and it would not fit the (COTS) category for sure and would seem at the very least to be unfair in the (SRAD) category.

Those at QCRC who are generally the mentors on Uni projects, actively discourage them from going hog wild, to the point they will revoke support and motors won't generally be sold to them. Granted, there is a way around it. It is not in their best interest though. The downside is when there is a big school and a professor that thinks his britches aren't big enough and goes rogue. From what I have seen, the professors that preside over the groups that QCRC mentors, they listen and follow. Again, from what I have seen. To the point where its like "Yeah no, you need half your team to get L1's, and then you need some L2's before we begin talking, so get going on it." Then its "Yeah no, you'll fly an M first before we talk N's or larger."

 

[AeroTech]

If you want to change course, it is best to know Gary just told us all how he's been helping/advising to write the NFPA codes for 40 years. He helped to write the codes that have constricted the market he now controls and he sits on the TRA Board of Directors. Think about that. How many businesses does NFPA 1125 cover in the US? One? What was the need for 1125 then and now? To keep manfs safe or to make it so difficult to comply with the code, that only a major player would ever dare even try.......

Scott, I tried to be gracious and publicly stated that I like you and your motors, but you are being extremely disingenuous in this paragraph. Clearly you don’t know the history of your own industry. I was invited by G. Harry Stine to participate on the NFPA Pyrotechnics Committee in the early ‘80s and was asked to help write code that made it MUCH easier for small composite propellant manufacturers to comply with the manufacturing regs. Otherwise you’d be stuck with the code that was basically written for the big black powder motor and fireworks manufacturers. The NFPA committees are “balanced” committees that include specific percentages of enforcers, special experts, regulators, users and manufacturers. I have ZERO conflict on the committee because I am fulfilling my appointed role as a manufacturer, which helps balance out the other interests. If you would like something changed, do what I and many other people have done and write a proposal! How do you think reloadables, metal cases, hybrids and sparkies came to be included? Your business only exists because of the efforts I and others made to allow products like yours to be sold legally! You’re welcome! The proposal forms are available on the NFPA website and in the back of every NFPA code document. Regarding my Tripoli board seat, I was elected to the board by the membership four times in my career. I am very careful to abstain from any vote that would be a conflict (which doesn’t happen very often at all), and the record is clear on that. If I was to do otherwise, the membership wouldn’t put up with it for a second! Regardless, I believe the board and Tripoli benefit by having manufacturer and dealer input. As I recall, the dealer board member you mentioned in an earlier post was also a Loki retailer!

 

[Neutronium95]

Maybe off base here with your specific intentions and/or goals of your university team but our club mentors a university for SLI and it’s full commercial motors only. We also mentor a university for ESRA IREC and it would not fit the (COTS) category for sure and would seem at the very least to be unfair in the (SRAD) category.

There is more to university rocketry than those competitions.

A good number of teams are working on various projects like space shot attempts that might benefit from an arrangement like this. I've heard of a few cases where a team wanted to do experimental motors, but couldn't get permission to mix propellant on campus. Having someone like Scott make the propellant for them could be a useful middle ground between making motors from scratch and staying with commercial motors for some specific applications.

 

[sharkbait]

There is more to university rocketry than those competitions.

A good number of teams are working on various projects like space shot attempts that might benefit from an arrangement like this. I've heard of a few cases where a team wanted to do experimental motors, but couldn't get permission to mix propellant on campus. Having someone like Scott make the propellant for them could be a useful middle ground between making motors from scratch and staying with commercial motors for some specific applications.

If you read the first statement, I said I may be off base with the intentions or goals of your university team, I was not implying that these were the only 2 events that universities participate in, merely pointing out that these two major competitions don’t seem to fit the bill for the proposed question from John’s post

 

[jderimig]

If you read the first statement, I said I may be off base with the intentions or goals of your university team, I was not implying that these were the only 2 events that universities participate in, merely pointing out that these two major competitions don’t seem to fit the bill for the proposed question from John’s post

To be fair I was not intending or even advising this approach with any university teams with regards to SLI or other rocket competitions. I was just creating a strawman for the discussion for a custom motor application not prohibited by NFPA but allowed to be flown under TRA. TRA research I assume and I hope goes beyond just mixing propellant by the user. RCS sells finished grains separately, I am assuming those are flying in TRA launches.

 

[Loki Research]

Here you go John. I gave it my best, but you'll probably give me a C-.

1) The complete removal of TMT Policies and Procedures section 10.7.2. Not reworded but completely removed.

2) Remove TMT P&P 11-4. Completely remove any TRA code verbiage that allows for 1) the decertification of any certified motors 2) decertification of a manufacturer’s entire motor line, or 3) revoking of a Manufacturers Approved status for any reason other than unreliable or problematic motor performance.

3) TRA (& NAR) to recognize and allow the exemptions of NFPA 1127 section 1.3.3(2) & 1.3.3(3) such that these entities are allowed the same privileges to fly any motor that an EX flier may currently fly, and be insured.

4) Change the TRA Unified Safety Code 10-6 to reflect NFPA 1127 6.1(4). It should be re-worded to state that it impacts only those entities who are not exempt from NFPA 1127, and by doing so, allow for the profitable sale of non-certified reloads to and from 1127 exempt entities. Note- the “making available” part below would need to be addressed as EX motors are currently now "made available" to others, contrary to 6.1(4) wording.
-Prohibited Activities, 6.1(4) Selling, offering for sale, exposing for sale, or making available a rocket motor or motor reloading kit that does not comply with the requirements of this code and that has not been certified in accordance with NFPA 1125.

5) The removal of all manufacturer's full responsibility for reimbursement of any motor acquired by TRA/TMT for "retesting" of a manufacturer’s motors that they believe is necessary. Delete TMT P&P code 11.2.1, 11.2.2 & 11.4. There may be others.

6) I would like to see the entire board submit NFPA proposals to address and clearly codify EX activities by certified L2 members who are not exempt from doing so under the current wording of 1127 code.

There are many separate sections of 1127 that specifically prohibit all of the EX activities currently allowed by the TRA.
1.2.3(2), 1.2.3(3), 6.1(3), 6.1(4), 6.1(5) & 6.1(8).
I do not seek to stop these activities at all but to have them clearly codified in 1127 for all to easily understand and abide by.

If 6.1(5) magically allows all these prohibited activities by L2 EX fliers (the group the entire document is intended to cover), then why in the world did they include all these other code entries I listed specifically to prohibit these very same activities from occurring? It is an obvious and complete contradiction of logic. Why does the NAR still not allow these things under the exact same code? Because one interpretation is honest and the other is manipulative.

Gary, I hope you can get behind this, whatever our differences may be.

 

[Loki Research]

Gary,

First, your quote of mine includes the following line from the end of the previous paragraph. “If you want to change course, it is best to know,” just incase it conveys the wrong meaning to people when put at the start of the next paragraph you quoted.

Helping to write 1127 back then may have seemed like a good thing for the hobby at the time, but decades later, we are now left with only two HPR motor manfs. It's too hard now for anyone else to enter the market without extremely deep pockets unless they operate in the country side like I do. If 1125 didn't tell you how many sheets you're allowed to wipe your back side with, I am positive that many small entrepreneurs would have entered the market by now.

I like your motors too. I’ve flown more Aerotech motors than I have of my own to date. However, I strongly disagree that you or any dealer having a seat on the board has absolutely no advantage at all over their competitors. Do you get any paid reimbursement to attend LDRS like the other members do for the annual board meeting? I don't know, but if so, I could use a paid trip to LDRS next year. I find it extremely difficult to believe that after 4 years on the board, you have never been privy to any useful information that I have not ever received. I have to trust you and the board of directors to believe that this never happens, and for the past decade, I have not held much if any trust in the leadership due to their past negative interactions with me. Now, after seeing that the board voted for Bob Brown, twice for president and my many previous negative interactions with him, I have absolutely zero trust or faith now in any TRA board member under his rule, and I am by far not at all alone.

 

[AeroTech]

Gary,

First, your quote of mine includes the following line from the end of the previous paragraph. “If you want to change course, it is best to know,” just incase it conveys the wrong meaning to people when put at the start of the next paragraph you quoted.

Helping to write 1127 back then may have seemed like a good thing for the hobby at the time, but decades later, we are now left with only two HPR motor manfs. It's too hard now for anyone else to enter the market without extremely deep pockets unless they operate in the country side like I do. If 1125 didn't tell you how many sheets you're allowed to wipe your back side with, I am positive that many small entrepreneurs would have entered the market by now.

I like your motors too. I’ve flown more Aerotech motors than I have of my own to date. However, I strongly disagree that you or any dealer having a seat on the board has absolutely no advantage at all over their competitors. Do you get any paid reimbursement to attend LDRS like the other members do for the annual board meeting? I don't know, but if so, I could use a paid trip to LDRS next year. I find it extremely difficult to believe that after 4 years on the board, you have never been privy to any useful information that I have not ever received. I have to trust you and the board of directors to believe that this never happens, and for the past decade, I have not held much if any trust in the leadership due to their past negative interactions with me. Now, after seeing that the board voted for Bob Brown, twice for president and my many previous negative interactions with him, I have absolutely zero trust or faith now in any TRA board member under his rule, and I am by far not at all alone.

Scott,

First, TRA and NAR safety codes generally follow the direction of NFPA code. If you want change, the best way to make that happen is to get involved in the NFPA process, not in a forum or by proxy, but in person. You are shouting at the wrong group. Don’t expect to win all your battles though, I’ve lost my share even with the most persuasive arguments.

Second, the primary reason there are currently three (not two) HPR motor manufacturers is that there is a limited market. Many HPR motor manufacturers have come and gone, and I don’t know any that went out of business because of NFPA 1127. My company certainly experienced its share of ups and downs that threatened its existence several times, that had nothing to do with NFPA.

I don’t remember any “inside information” discussed in TRA board meetings that gave me a competitive advantage against you or CTI. In fact I recall at least once that there was a meeting where I was recused because of a potential conflict. On the contrary, you will recall that a few years ago I shared information about TRA’s plans to re-certify every single motor with you and Anthony, much to the chagrin of several board members. Talk about biting the hand that feeds you!! However, I am proud of the fact that the three of us worked together to help bring about meaningful and much-needed reform to the process.

TRA directly/up front (I.e., not by reimbursement) covers the cost of rooms for board members required to attend LDRS and BALLS meetings. Other board members may receive reimbursement for food and travel expenses they incur. If you need/want your room covered at these two launches, run for the board!

Bottom line Scott is that you should get involved with the process as others have, in a calm and rational manner, and not merely complain about these things on public forums. This was exactly the advice that G. Harry gave me when I was starting out, and I’ve never regretted following it since.

 

[AlexBruccoleri]

5) The removal of all manufacturer's full responsibility for reimbursement of any motor acquired by TRA/TMT for "retesting" of a manufacturer’s motors that they believe is necessary. Delete TMT P&P code 11.2.1, 11.2.2 & 11.4. There may be others.

I have not read all the TMT P&P codes, and I suspect many forum members have not either. Can you clarify what the rules say is necessary for retesting?

Also can you review the NAR rules and see what differences exists for motor decertification?

 

[dhbarr]

I have not read all the TMT P&P codes, and I suspect many forum members have not either. Can you clarify what the rules say is necessary for retesting?

TRA Motor Testing Policies and Procedures

NAR Standards & Testing Committee Motor Testing Manual

 

[sharkbait]

TRA Motor Testing Policies and Procedures

NAR Standards & Testing Committee Motor Testing Manual

I’m starting to get sea sick

 

[jsdemar]

Here you go John. I gave it my best, but you'll probably give me a C-.

1) The complete removal of TMT Policies and Procedures section 10.7.2. Not reworded but completely removed.

2) Remove TMT P&P 11-4. Completely remove any TRA code verbiage that allows for 1) the decertification of any certified motors 2) decertification of a manufacturer’s entire motor line, or 3) revoking of a Manufacturers Approved status for any reason other than unreliable or problematic motor performance.

3) TRA (& NAR) to recognize and allow the exemptions of NFPA 1127 section 1.3.3(2) & 1.3.3(3) such that these entities are allowed the same privileges to fly any motor that an EX flier may currently fly, and be insured.

4) Change the TRA Unified Safety Code 10-6 to reflect NFPA 1127 6.1(4). It should be re-worded to state that it impacts only those entities who are not exempt from NFPA 1127, and by doing so, allow for the profitable sale of non-certified reloads to and from 1127 exempt entities. Note- the “making available” part below would need to be addressed as EX motors are currently now "made available" to others, contrary to 6.1(4) wording.
-Prohibited Activities, 6.1(4) Selling, offering for sale, exposing for sale, or making available a rocket motor or motor reloading kit that does not comply with the requirements of this code and that has not been certified in accordance with NFPA 1125.

5) The removal of all manufacturer's full responsibility for reimbursement of any motor acquired by TRA/TMT for "retesting" of a manufacturer’s motors that they believe is necessary. Delete TMT P&P code 11.2.1, 11.2.2 & 11.4. There may be others.

6) I would like to see the entire board submit NFPA proposals to address and clearly codify EX activities by certified L2 members who are not exempt from doing so under the current wording of 1127 code.

There are many separate sections of 1127 that specifically prohibit all of the EX activities currently allowed by the TRA.
1.2.3(2), 1.2.3(3), 6.1(3), 6.1(4), 6.1(5) & 6.1(8).
I do not seek to stop these activities at all but to have them clearly codified in 1127 for all to easily understand and abide by.

If 6.1(5) magically allows all these prohibited activities by L2 EX fliers (the group the entire document is intended to cover), then why in the world did they include all these other code entries I listed specifically to prohibit these very same activities from occurring? It is an obvious and complete contradiction of logic. Why does the NAR still not allow these things under the exact same code? Because one interpretation is honest and the other is manipulative.

Gary, I hope you can get behind this, whatever our differences may be.

I'll give you a B+.
Here's some more feedback and advice. I might have to double my hourly rate!

1) If a manufacturer violates the requirements for a legal licensed business, that company is no longer considered "a Commercial Manufacturer" as defined by NFPA 1125. If a company simply goes out of business, there's no violation, and their motors fall under the expiration rules.
Chance of modification: 10%.

2) A decertified motor isn't the same as an expired motor. A motor is primarily decertified for safety reasons. That is the only reason given in NFPA 1125. The other reason (added by TMT) is due to a violation as a 'Commercial Manufacturer' as explained above in (1). Expired motors may be used until the stock is depleted.
Chance of modification: 40%. An argument could be made that, although a manufacture is no longer licensed, the existing motor stock should be usable at a launch as long as there's no SAFETY reason for decertifying. The judgement call come into play when the illegal manufacturer still exists: it's impossible to determine old stock vs new stock.

3) NFPA 1127 by definition is for consumer HPR. Tripoli Rocket Association according to its bylaws was formed for individuals. So, if an entity is not an individual(*a) taking part as a consumer of HPR motors, NFPA 1127 doesn't apply. If an individual is taking part in... research... or ...testing...(*b) [see 1127 1.3.3(2)], NFPA 1127 doesn't apply.
Let's look at each of these cases:
(*a) TRA is not an organization which allows membership by anything other than an individual taking part as a non-business, non-government entity. The privileges of TRA membership (e.g. insured launches) do not extend beyond the individual member.
(*b) TRA members (as a person, not a business!) are exempt from NFPA 1127 by definition when doing research and testing. TRA has set safety codes which allow this activity within the scope of the insurance policy. This doesn't exempt anyone from other laws/regulation/local codes, etc. That's up to the individual to determine.
Chance of modification: 0%. If you're not an individual and want to launch something, get your own insurance. Otherwise, you're a risk/cost burden to the individual members of TRA (or NAR).

4) Since NFPA 1125/1127 are for individual consumer rocketry only, there's no reason to explicitly state who it's NOT for. This is a standard method in writing codes and regulations: state it up front so you don't have to list everything it doesn't apply to. Should we say it doesn't cover your dog flying rockets?!
Nothing says you can't sell for profit to any other entity which isn't a party to the NFPA 1125/1127 codes. Of course, as a business you need to check all of the other laws/regulations which might apply. DOT transport "in commerce" still applies, for example.
Chance of modification: doesn't apply.

5) TMT/NARS&T should only request retesting if there's a reported safety issue. Usually, if the manufacture is responsive and proactive, there's no need for re-testing. It's up to the organizations policy to decide what to do for the cost of testing. It applied to all manufacturers. If a company wishes to take part in this market, it has to comply with the cost of doing business. If a company cannot afford the expense of sending a couple motor to TMT, it should consider a different customer base.
Chance of modification: 0%.

6) I'm not sure what you mean by "not exempt from doing so" under 1127. It's very clear as defined now. You can't bring into 1127 entities it doesn't apply to (e.g. universities, businesses). In addition, TRA has set policy to require L2 for Research activities to minimize risk.
Chance of modification: doesn't apply.

Summary: you are free to do business with whomever you want as long as they are exempt from NFPA 1125/1127 and you are not asking TRA/NAR to insure entities who are not allowed as members of their organizations.
If there are other clarifications needed for Research activity by individual members of Tripoli, you can ask the TRA board or propose something to the Tripoli Research Committee.

(Note: the above is my interpretation and not that of any organization!)

 

[cerving]

Six pages, and the OP still hasn't logged back in since his ONE AND ONLY post... if that ain't a bot or a troll, I don't know what is.

 

[AeroTech]

I'll give you a B+.
Here's some more feedback and advice. I might have to double my hourly rate!

1) If a manufacturer violates the requirements for a legal licensed business, that company is no longer considered "a Commercial Manufacturer" as defined by NFPA 1125. If a company simply goes out of business, there's no violation, and their motors fall under the expiration rules.
Chance of modification: 10%.

2) A decertified motor isn't the same as an expired motor. A motor is primarily decertified for safety reasons. That is the only reason given in NFPA 1125. The other reason (added by TMT) is due to a violation as a 'Commercial Manufacturer' as explained above in (1). Expired motors may be used until the stock is depleted.
Chance of modification: 40%. An argument could be made that, although a manufacture is no longer licensed, the existing motor stock should be usable at a launch as long as there's no SAFETY reason for decertifying. The judgement call come into play when the illegal manufacturer still exists: it's impossible to determine old stock vs new stock.

3) NFPA 1127 by definition is for consumer HPR. Tripoli Rocket Association according to its bylaws was formed for individuals. So, if an entity is not an individual(*a) taking part as a consumer of HPR motors, NFPA 1127 doesn't apply. If an individual is taking part in... research... or ...testing...(*b) [see 1127 1.3.3(2)], NFPA 1127 doesn't apply.
Let's look at each of these cases:
(*a) TRA is not an organization which allows membership by anything other than an individual taking part as a non-business, non-government entity. The privileges of TRA membership (e.g. insured launches) do not extend beyond the individual member.
(*b) TRA members (as a person, not a business!) are exempt from NFPA 1127 by definition when doing research and testing. TRA has set safety codes which allow this activity within the scope of the insurance policy. This doesn't exempt anyone from other laws/regulation/local codes, etc. That's up to the individual to determine.
Chance of modification: 0%. If you're not an individual and want to launch something, get your own insurance. Otherwise, you're a risk/cost burden to the individual members of TRA (or NAR).

4) Since NFPA 1125/1127 are for individual consumer rocketry only, there's no reason to explicitly state who it's NOT for. This is a standard method in writing codes and regulations: state it up front so you don't have to list everything it doesn't apply to. Should we say it doesn't cover your dog flying rockets?!
Nothing says you can't sell for profit to any other entity which isn't a party to the NFPA 1125/1127 codes. Of course, as a business you need to check all of the other laws/regulations which might apply. DOT transport "in commerce" still applies, for example.
Chance of modification: doesn't apply.

5) TMT/NARS&T should only request retesting if there's a reported safety issue. Usually, if the manufacture is responsive and proactive, there's no need for re-testing. It's up to the organizations policy to decide what to do for the cost of testing. It applied to all manufacturers. If a company wishes to take part in this market, it has to comply with the cost of doing business. If a company cannot afford the expense of sending a couple motor to TMT, it should consider a different customer base.
Chance of modification: 0%.

6) I'm not sure what you mean by "not exempt from doing so" under 1127. It's very clear as defined now. You can't bring into 1127 entities it doesn't apply to (e.g. universities, businesses). In addition, TRA has set policy to require L2 for Research activities to minimize risk.
Chance of modification: doesn't apply.

Summary: you are free to do business with whomever you want as long as they are exempt from NFPA 1125/1127 and you are not asking TRA/NAR to insure entities who are not allowed as members of their organizations.
If there are other clarifications needed for Research activity by individual members of Tripoli, you can ask the TRA board or propose something to the Tripoli Research Committee.

(Note: the above is my interpretation and not that of any organization!)

Thanks for going through that, John. I didn't have the patience or attention span required today...

 

[AlexBruccoleri]

(*b) TRA members (as a person, not a business!) are exempt from NFPA 1127 by definition when doing research and testing. TRA has set safety codes which allow this activity within the scope of the insurance policy. This doesn't exempt anyone from other laws/regulation/local codes, etc. That's up to the individual to determine.

Are you stating this due to 6.1(5) or 1.3.3(2)? Both seem to allow TRA members the ability to do research work.

 

[Loki Research]

(*b) TRA members (as a person, not a business!) are exempt from NFPA 1127 by definition when doing research and testing. TRA has set safety codes which allow this activity within the scope of the insurance policy.

Show me how this is remotely true John. 1.3.3(2) exemption requires a licensed business. That is not simply an individual doing research for fun.
If individual fliers are exempt to make home made motors, experiment with them, modify and tamper with certified reloads, make available non-certified motors to others, etc., then why are codes 1.2.3(2), 1.2.3(3), 6.1(3), 6.1(4), 6.1(5) & 6.1(8) wrote into the document at all?
Who are these codes intended to cover then if not for the certified flier?
They aren't for non-certified members, because only certified members may obtain HPR reloads and motors that could later be modified or used improperly per the codes listed above.

People keep telling me they can't make these changes to TRA codes, because of NFPA. That is flat out wrong.
NFPA does not need to change for anything I have asked but item 6.

6.1(5) is the official reason that Steve gives for allowing EX.
What specifically changed in 1127 6.1(5) between 2002 (when EX activities were not allowed) and now, when they are allowed?
Every word in 6.1(5) is identical from then until now. For 20 years that code has not changed.
Why do I ask this again? Because no one has YET to answer the following.

If 6.1(5) wording did not change at all, then how in the world did the TRA make EX activities possible without a single word change in 6.1(5)? How?
Because the TRA changed their interpretation and NAR did not. So if they can make an EX change to TRA code WITHOUT the NFPA code changing, then why can they make these changes I listed? They can surely make each and every change I am proposing with ease, because the changes are in their own codes, not NFPA, and the changes I am proposing are in line with 1127.

Yes, the TRA has the ability to write code that could drive me out of business if used improperly (TMT P&P 10.7.2 and others) and they also have the ability to wright codes that make business easier for me to grow and succeed (selling motors to exempt entities and allowing their flights by code), and for others to possibly follow, but in doing the latter, Gary will likely have more competition from me. Which direction does the membership want? It is their club, but not until they make it their club.