New Jerry Irvine Motor Company

[Neutronium95]

A friend of mine showed me this ad, which is in some hobby industry magazine. Needless to say I am very skeptical of the claims in the fine print. I don't see how it is possible to make motors thay are exempt from all of those regulatory agencies, woth the exception of motors with less than 125g of propellant not needing a FAA waiver. And even if they were exempt from government regulation, I see no way that they'd be exempt from NAR or Tripoli rules at launches. According to his Linkedin, Jerry Irvine is heavily involved.

 

[cwbullet]

Not sure if there is a relation ship, but:

https://www.rocketryforum.com/threads/exempt-rocket-motors-defined.176674/page-2#post-2365722

 

[Neutronium95]

Not sure if there is a relation ship, but:

https://www.rocketryforum.com/threads/exempt-rocket-motors-defined.176674/page-2#post-2365722

That thread is more about legal technicalities on the limits on legitimate manufacturers, honestly I can't really follow some of the more detailed discussion. I didn't want to side track it with a discussion about motors that almost certainly are not in fact exempt from all federal regulation.

 

[cwbullet]

That thread is more about legal technicalities on the limits on legitimate manufacturers, honestly I can't really follow some of the more detailed discussion. I didn't want to side track it with a discussion about motors that almost certainly are not in fact exempt from all federal regulation.

I think that is the question. Time till tell on this new company. If ti is not truly exempt, the FEDs will find it soon enough and it will be short-lived. I suspect there is something to his claim of an exemption. It would be foolish to be so public with that ad if not.

 

[Neutronium95]

I think that is the question. Time till tell on this new company. If ti is not truly exempt, the FEDs will find it soon enough and it will be short-lived. I suspect there is something to his claim of an exemption. It would be foolish to be so public with that ad if not.

I just don't see any way that any solid rocket fuel could be exempt from all BATFE and DOT regulation. Rocket fuel is just too energetic and eager to burn that it has to at least fall under some sort of DOT regulation. If you stick to motors with less than 125g of propellant, the FAA won't care, but they also won't care if you fly a UDMH/NTO liquid bipropellant rocket that manages to stay under the class 1 mass limits. Weirdly enough, the only regulatory agency he seems to be following is the CSFM, since he isn't planning on selling them in California.

I'm sure that Jerry has some secret ingredient or paperwork loophole that he thinks will make his motors exempt from regulation. I highly doubt that whatever it is will actually allow him to ship motors legally without a DOT ex number. And they certainly won't be exempt from Tripoli or NAR rules, except for the fact that anyone can fly outside of a Tripoli or NAR launch if they're willing to arrange for a launch site, get a waiver, and pay for insurance.

 

[Steve Shannon]

No high power rocket motors are exempt from NFPA 1125 or NFPA 1127.

APCP is not regulated by ATF (thanks to the lawsuit by Tripoli and NAR years ago.)

I have no idea how any manufacturer could claim such exemption.

 

[lakeroadster]

Web address doesn't work. There is an actionrocket.com but nothing for actionrockets.com

 

[cwbullet]

No high power rocket motors are exempt from NFPA 1125 or NFPA 1127.

APCP is not regulated by ATF (thanks to the lawsuit by Tripoli and NAR years ago.)

I have no idea how any manufacturer could claim such exemption.

Thanks for the explanation. Odd that he would publish this to the public.

 

[tsmith1315]

I have no idea how any manufacturer could claim such exemption.

Maybe they’re just model airplane parts.

 

[cerving]

These look like model rocket motors, and the H's probably contain under 125 grams of propellant so they're not FAA 101 (Aerotech sells a few motors like that too). I would assume that's what they are referring too... not some kind of magic exemption from the rules.

 

[Steve Shannon]

Thanks for the explanation. Odd that he would publish this to the public.

Not if you are familiar with his history. He has been making such statements on Facebook for a while now. Jerry’s an interesting guy and knows more about making rocket motors than I probably ever will, but he’s another of those folks who thinks he’s somehow above the rules that everyone else play by.

 

[Charles_McG]

Over on YORF, he had been claiming (but not disclosing) a new composition of matter (my wording, not his) that wasn’t covered by existing regulations.

My thought at the time was that he either misunderstood how regulatory systems work, or that he was using the letter against the spirit.

I’ve had my own experience of trying to play word games with regulators, and ended up sitting for 4 years on a useless federal distilled spirits plant registration while I got state law changed.

It’s the regulators’ ball and the regulators’ game. If you disagree on interpretation, a judge decides - not a discussion with the regulator.

 

[StreuB1]

Maybe they’re just model airplane parts.

I chuckled way too hard at this. lol

Not if you are familiar with his history. He has been making such statements on Facebook for a while now. Jerry’s an interesting guy and knows more about making rocket motors than I probably ever will, but he’s another of those folks who thinks he’s somehow above the rules that everyone else play by.

Indeed. Jerry is a wildly intelligent person and extremely experienced in solid motors and their development.

His downside and his hallmark though, is that he is always (and always has been) the type to look for "the angle" instead of just charging forward and developing and producing technology.

I can go back to some of my earliest conversations with him on propulsion from the early 90's when I was a teenager and it was the exact same then. Its kind of comical and I am sure people out there will agree when I say "It's just Jerry."

 

[Steve Shannon]

I chuckled way too hard at this. lol




Indeed. Jerry is a wildly intelligent person and extremely experienced in solid motors and their development.

His downside and his hallmark though, is that he is always (and always has been) the type to look for "the angle" instead of just charging forward and developing and producing technology.

I can go back to some of my earliest conversations with him on propulsion from the early 90's when I was a teenager and it was the exact same then. Its kind of comical and I am sure people out there will agree when I say "It's just Jerry."

Exactly! When I was a moderator on Rocketry Planet we tried to put up with him. I was very interested in learning about what he knew about motors, but then he would eventually say something that we just couldn’t ignore. The last time was just something extremely mean spirited and distasteful towards another person who is well known in our hobby, whose wife had died, and who had later found a new love.

 

[ThirstyBarbarian]

This hobby attracts a lot of smart but kooky people.

 

[AeroTech]

These look like model rocket motors, and the H's probably contain under 125 grams of propellant so they're not FAA 101 (Aerotech sells a few motors like that too). I would assume that's what they are referring too... not some kind of magic exemption from the rules.

He's claiming they're exempt from hazmat shipping regulations, among other things, due to some special ingredient(s). However, he also acknowledges that they are APCP.

 

[AeroTech]

This hobby attracts a lot of smart but kooky people.

In my experience, drug and alcohol abuse seems to explain a lot of strange behavior from certain individuals.

 

[FredA]

In my experience, drug and alcohol abuse seems to explain a lot of strange behavior from certain individuals

I find this unnecessary and inappropriate here.

 

[AeroTech]

I find this unnecessary and inappropriate here.

It's true. I've seen it multiple times in my own family. My daughter died from it. Sweeping the problem under the rug helps no one.

 

[Steve Shannon]

In my experience, drug and alcohol abuse seems to explain a lot of strange behavior from certain individuals.

It reminds me of the old Bill Cosby routine:
Cosby: Why do you do drugs?

I find that it enhances my personality!

Cosby: Yes, but what if you’re an a-hole?

Drugs and alcohol never improve any of us.

 

[rfjustin]

What hobby industry magazine was this published in please?

 

[AeroTech]

What hobby industry magazine was this published in please?

Hobby Merchandiser, December issue. It's a hobby trade publication.

 

[sharkbait]

He's claiming they're exempt from hazmat shipping regulations, among other things, due to some special ingredient(s). However, he also acknowledges that they are APCP.

Apples and oranges but somehow MJG got around it with initiators with their FireWire starters

 

[AeroTech]

Apples and oranges but somehow MJG got around it with initiators with their FireWire starters

They get around ATF regulation but not hazmat shipping, unless they ship USPS Parcel Post like rocket motors under 30 grams propellant. USPS has their own rules separate and apart from DOT, but they rely on DOT classification designations to determine what is mailable.

 

[boatgeek]

Recognizing that Jerry Irvine has a history and that I don't really know it, but also trying to assume positive intent. The ad says that the motors are exempt from a variety of regulations.

BATFE: It's sort of reasonable to say that APCP motos are exempt from BATFE rules since the lawsuit. There may be rules that operate in the background for manufacturers that I'm missing, though.

DOT and HMR: This is the one I'm having the most trouble with. My understanding is that the average Joe can't ship rocket motors even if they aren't hazmat. While it's possible that these are LMS-style motors with <30g/grain that wouldn't require hazmat shipping, saying that you're exempt from DOT regs because they're not hazmat is a pretty big stretch. If he's selling to brick-and-mortar stores only, it's not quite as bad since they don't need any particular DOT certifications to sell the motors in their stores as long as they don't mail them.

FAA: It looks reasonable based on the CTI catalog that these could all be <125g of propellant (the 29mm 5G H200 has 260 N-s of impulse and a hair over 125g of propellant). That means that these could fly as Class 1 motors. While it's a stretch to say that means they're exempt from FAA regulations, I can see how one could get there.

NFPA: I don't know enough about NFPA, but I trust @Steve Shannon's statement that NFPA 1125/1127 applies to all HPR motors. There might be an out if the NFPA rules don't apply specific restrictions on the end user, but that's a long leap.

Club rules: Well, this is the sticking point. NAR and TRA can set their own rules, and exclude non-certified motors sold for profit. That said, there's no reason that the motors couldn't be certified. That would be pretty cheap given that these are F-H motors.

They get around ATF regulation but not hazmat shipping, unless they ship Parcel Post like rocket motors under 30 grams propellant.

They do ship parcel post, presumably in the <30g propellant category. In the same vein as the LMS motors, couldn't you say that each igniter has <30g propellant so the bundle of 100 doesn't ship hazmat?

 

[AeroTech]

Recognizing that Jerry Irvine has a history and that I don't really know it, but also trying to assume positive intent. The ad says that the motors are exempt from a variety of regulations.

BATFE: It's sort of reasonable to say that APCP motos are exempt from BATFE rules since the lawsuit. There may be rules that operate in the background for manufacturers that I'm missing, though.

DOT and HMR: This is the one I'm having the most trouble with. My understanding is that the average Joe can't ship rocket motors even if they aren't hazmat. While it's possible that these are LMS-style motors with <30g/grain that wouldn't require hazmat shipping, saying that you're exempt from DOT regs because they're not hazmat is a pretty big stretch. If he's selling to brick-and-mortar stores only, it's not quite as bad since they don't need any particular DOT certifications to sell the motors in their stores as long as they don't mail them.

FAA: It looks reasonable based on the CTI catalog that these could all be <125g of propellant (the 29mm 5G H200 has 260 N-s of impulse and a hair over 125g of propellant). That means that these could fly as Class 1 motors. While it's a stretch to say that means they're exempt from FAA regulations, I can see how one could get there.

NFPA: I don't know enough about NFPA, but I trust @Steve Shannon's statement that NFPA 1125/1127 applies to all HPR motors. There might be an out if the NFPA rules don't apply specific restrictions on the end user, but that's a long leap.

Club rules: Well, this is the sticking point. NAR and TRA can set their own rules, and exclude non-certified motors sold for profit. That said, there's no reason that the motors couldn't be certified. That would be pretty cheap given that these are F-H motors.


They do ship parcel post, presumably in the <30g propellant category. In the same vein as the LMS motors, couldn't you say that each igniter has <30g propellant so the bundle of 100 doesn't ship hazmat?

The MJG igniters are likely classified as UN0454 and contain only a few milligrams of material each. They should be able to ship up to the maximum gross weight limit of 25 pounds.

 

[Steve Shannon]

NFPA: I don't know enough about NFPA, but I trust @Steve Shannon's statement that NFPA 1125/1127 applies to all HPR motors. There might be an out if the NFPA rules don't apply specific restrictions on the end user, but that's a long leap.

Cherry picking your post:
In the locations where they are adopted, NFPA 1122 governs the use (end user) of model rockets, NFPA 1127 governs the use (end user) of high power rockets, and NFPA 1125 governs the manufacture of all model rocket motors and all high power rocket motors up through O motors.
It doesn’t matter if a motor is completely exempt from DOT. For instance, hybrids are because they ship in an inert state.

 

[Johnly]

Items can be exempted from DOT regulations, but that requires testing of your product by accredited laboratories using DOT protocols.
I emphasize "your products" as one can not just say to DOT that it's just like a similar item made by another company, and therefore it's an exempt item.

 

[Neutronium95]

Club rules: Well, this is the sticking point. NAR and TRA can set their own rules, and exclude non-certified motors sold for profit. That said, there's no reason that the motors couldn't be certified. That would be pretty cheap given that these are F-H motors.

There is one reason why these motors won't be certified. From what I understand, both NAR and Tripoli require that a manufacturer have a DPT ex number for the propellant before they'll accept a motor for testing and certification.

 

[shockie]

I just wanna know why JI isn't sitting in a federal prison somewhere. He must be selling some of those exempt motors under NFPA 1127 section 1.3.3 because he got himself a business license. But there is no such exemptions under 1125 except for military,other agencies or political subdivisions.

Maybe JI has succeeded from CA?

Plus he's manufacturing in California which have their own fire codes. If I remember correctly you have to have a pyrotechnics license in CA to import or export rocket motors .

Gary @ AT would know the answer to this.