And NFPA 1127 exempts certain entities from its code, like Loki Research, but you have not acknowledge this. if you did, you would be in compliance with 1127.
You have verbally told me that the TRA Research user exemption is based on the wording in 1127 6.1(5).
Show me the the specific part of NFPA 6.1(5) that changed between the 2002 code version when research motors were banned, and the 2022 version or prior when they became allowed. The wording is identical in every 1127 version I have found from 2002 until 2022.
1127 - 6.1(5) Making, operating, launching, flying, testing, activating,
discharging, or otherwise experimenting with high power
rocket motors, motor reloading kits, or pyrotechnic modules
that have not been certified in accordance with
NFPA1125, Code for the Manufacture of Model Rocket and High
Power Rocket Motors, other than for the purpose of evaluation
of new high power rocket motor technology by a recognized
national user organization or an authority having
jurisdiction, provided that all other requirements of this
code are met and all activities are in accordance with applicable
laws, regulations, and ordinances.
If a member of a National User Organization is exempt from 1127 - 1.2.3(2), 1.2.3(3), 6.1(3), 6.1(4), 6.1(5) & 6.1(8) then why is that group NOT listed in the exemptions of 1127 1.3.3?
1.3.3 This code shall not apply to the design, construction,
production, manufacture, fabrication, maintenance, launch,
flight, test, operation, use, or other activity connected with a
rocket or rocket motor where carried out or engaged in by the
following entities:
(1) National, state, or local government
(2) An individual, a firm, a partnership, a joint venture, a
corporation, or other business entity engaged as a licensed
business in the research, development, production,
testing, maintenance, or supply of rockets, rocket
motors, rocket propellant chemicals, or rocket components
or parts
(3) College or university
Individuals not engaged in business do not apply here. Site me the code where they are allowed and how it changed from previous versions. If you can do that, I'll appologize to you and admit that there was a change in 1127 that I was not aware of.
I have previously stated that these motors have not been and will not be available to the public, by definition, but you seemed to have glossed over and ignored those statements.
Scott,
You’re mixing up the meanings of exception, exemption, and out of scope.
Scope
Manufacturers are out of scope of NFPA 1127. That means that none of 1127 directly governs their actions
Manufacturers are completely in-scope for 1125.
Individuals flying rockets and organizations holding launches are completely in-scope of 1127.
Individuals making motors for their own use are out of scope of 1125.
Exception
An exception is very narrow window in a requirement to provides for limited deviation from the rule being presented. Although our launches must comply with 1127, the wording that you quoted here from 1127 provides an
exception to the prohibition on making motors for members of a national user organization:
1127 - 6.1(5) Making, operating, launching, flying, testing, activating,
discharging, or otherwise experimenting with high power
rocket motors, motor reloading kits, or pyrotechnic modules
that have not been certified in accordance with
NFPA1125, Code for the Manufacture of Model Rocket and High
Power Rocket Motors,
other than for the purpose of evaluation
of new high power rocket motor technology by a recognized
national user organization or an authority having
jurisdiction,
provided that all other requirements of this
code are met and all activities are in accordance with applicable
laws, regulations, and ordinances.
As I’ve posted above, Tripoli is a recognized national user organization and in my interpretation this allows our members to make their own motors, subject to the additional requirements of the Tripoli Safety Code. This is an exception, meaning it only applies to this one requirement. In fact the last clause in this requirement stipulates that all the other requirements in this code (1127) remain in place. That very deliberately means that the entire text of the requirements of 1127 must be considered in context with one another.
Specifically, the prohibition (5) from 1127 that you and I posted above must be considered in context with the one which immediately preceded it. I’ll post them together here so the context is whole:
(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) Making, operating, launching, flying, testing, activating, discharging, or otherwise experimenting with high power rocket motors, motor reloading kits, or pyrotechnic modules that have not been certified in accordance with NFPA 1125 other than for the purpose of evaluation of new high power rocket motor technology by a recog‐ nized national user organization or an AHJ, provided that all other requirements of this code are met and all activities are in accordance with applicable laws, regulations, and ordinances
So, speaking for myself only as only one of nine members of the board, I feel that these two prohibition together establish that a non-certified high power motor manufactured by a commercial manufacturer is prohibited by 1127, which directly affects our actions at a launch. It doesn’t matter if
you are out of scope as a manufacturer; our members and our launch are in-scope of this and all other requirements of 1127.
To further support my position is this statement in the scope portion of NFPA 1125, which you are in-scope and which requires certification of commercial motors:
1.1.7 This code shall not apply to the fabrication of model rocket motors or high-power rocket motors by individuals for their personal use.
I wasn’t on the board or a member of the NFPA Pyrotechnics Technical Committee in 2002. I am not claiming that anything changed. This is simply my interpretation, but my conversations with others on the committee have led me to believe that Tripoli Research is in a good place, but that rocking the boat at NFPA by suggesting changes could result in changes that we hadn’t anticipated and which we would not want.
Lastly, whatever you choose as your business model is totally up to you, but I will resist any changes to NFPA Codes or the Tripoli Safety Code that I feel would not be beneficial to our member abilities to participate in high power and research rocketry.
Tripoli has no obligation to provide launch facilities or insurance to those entities which are out of scope of 1127. They are, in every case, official or professional organizations which have a responsibility to provide their own facilities, insurance, risk assessment, and waiver. By including those organizations we would raise our exposure to claims which could result in higher priced insurance. The cost of insurance has gone up substantially as it is.
John Demar has provided you with a road map of what you can try. Gary has recommended that you get involved with NFPA. Me? I’m going back to bed.
p.s. If Tripoli decided to fly in the face of NFPA requirements by allowing motors manufactured commercially without certification and sold to our members to be used at our launches, that would open up the market to a lot more “exempt” manufacturers. You might want to consider how that competition might affect your sales.
