POLL: NFPA 1122 VS State Exemptions & the NAR MRSC

[shockwaveriderz]

I had asked 2 polls about the NARMRSC or the NAR/TRAHPRSC being placed in each kit/motor sold.

And of course I had an ulterior motive.

So I would like you to take the time to read the following and answer another poll.

thanks for your time

terry dean
nar 16158





Doing a cursory google search, I found 6 states that EXEMPT model rockets/motors from their fireworks laws. 2 of the 6 also exempt the same from their explosives laws.

I know this is just a small sample, but why, from your POV, are NFPA XXXX even needed in these states?

In most states that have Exemptions for model rocketry, I don't fully understand why the state also needs any NFPA regulation for model rockets.

Especially when these NFPA regulations are being openly and directly adopted by the state fire marshal. I'm trying to point out that in some cases, the NFPA "trinity" were adopted thru other means; namely NFPA 1 Chapter 65 and if theu adopt then IFC, Chapters 33 or 34.

And in just in case yoy are wondering what these chapters say, basically they adopt NFPA 1122/25/27.

I discovered these what I call "stealth" regulations purely by chance several years ago so I asked the then and current NFPA Liason J. Patrick Miller, what the backstory was on these Chapters. He told me that the NFPA modle rocket codes were not being adopted by many if not most state fire marshals ( as the NAR weanted them to), so they decided to stick this "stealth" code into NFPA 1 and the IFC, thus covertly getting state fire marshals to adopt NFPA 1 and the IFC, and then adopting the NFPA "trinity" by default.

Doesn't this take away the respective state fire marshal's choice to adopt or not to adopt fire code as he sees fit for his state? I mean should it not be the respective state marshal's choice on whether his state adopts a specific fire code? Versus adoption by stealth ?

Up until 1967/68 there were NO NFPA model rocketry firecodes in existence in any state that I can find. During this time frame model rocketry grew by leaps and bounds in most states; Most of the states at this time didn't even yet have any exemptions for model rockets from their fireworks codes, but the local and state fire marshal's evidently made the informed decision that model rockets were not fireworks so they never really enforced such laws.

For example, the state of Kentucky didn't pass their Model Rocketry exemption law unto 1981!. BUT model rocket kits and motors were freely available at most hobby shops in the state since at least 1966. It wasn't until 2007 that the state of Kentucky adopted NFPA 1.

So Kentucky went 40 years without any NFPA model rocket regulations, and model rocketry had flourished just fine thank you. Did Kentucky become any safer by adopting the NFPA regs?

I actually called and talked to this fire marshal, and asked him if he was familar with Chapter 65 in NFPA 1. He had to look it up first. Then I had to explain to him what NFPA 1122/25/27 were. And his response was this: "If I had known that Chapter 65 was in NFPA 1 and that Chapter 65 adopted NFPA 1122/25/27 I would not have adopted the Chapter 65."


I wonder how many other states have unknowingly adopted the NFPA Trinity without knowing that they were even doing so. This is what is so insidious about regulation: Once you get a regulation adopted, it can almost be impossible to get such regulation rescinded.


I can see one argument coming forth: Well by having the NFPA trinity it gives a baseline uniform regulation to model rocketry, so that model rocketry is treated equally across state lines. But we already have a handfull of states that do things differently from the NFPA codes and other states: New Jersey, Rhode Island and of course California. This is true, but WHY in the world have a national regulation if its never been enforced and never will be enforced.

Some will argue, that with only a state exemption on the books, a state legislature could rescind it. This is true, but Fire Marshal's can also do the same for fire codes.

Some will argue that a city or jursdiction might make model rocketry illegal in their jurisdiction for those states that have exemptions. Folks, we all know that a city council or other local governemental entity can pass a simple ordinance to prohibit modle rocketry even in states with exemptions of fire codes for that matter. SO the NFPA regulations are no defense against that happening.

So why do we have this regulation if:

1. Its not enforceable
2. and a state has its own Exemption in place?

Some or most of these states have had this fireworks or explosives exemptions in place for literally years before any NFPA/IFC fire codes where even implemented; years in which their were no major accidents, so the argument, at least as these states are concerned, never had ANY Safety problems with model rocketry.

Isn't that kind redundant?

Model Rocketry has been around now for 50 years. In that time literally hundred of millions of flights have occured all over these United States. Millions upon Millions of children and adults have been exposed to modelrocketry; and nobody can point to more than a handfull of accidents or injuries.

Model Rocketry has got to be one of the safest hobbies ever known.

I would argue that NFPA 1122 is not needed. I would argue that model rocketry needs to be completely de-regulated out of the NFPA's hands. I think NAR policy should be to work in trying to create and pass an exemption for model rocketry in each state, and get NFPA 1122 out of these states.

So now you know why I asked the question:

If you had the choice between NFPA 1122 versus a state exemption and the NAR MRSC for guidance, which would you choose?

If Model rocketry is indeed as safe as the stats bear out, what need is there for NFPA 1122? The majority of people who purchase model rocketry products have no idea that it even exists. So its not like they are even following anything in it. And since its not enforceable and never will be, why do we adopt it? Is NFPA 1122 regulation solely for the sake of regulation?

I am not advocating that the NAR remove itself from the NFPA PYRO AAA technical Committee; I believe it should be there to prevent even more regulation that might come up from its other members.

 

[rstaff3]

I think my brain just exploded.

 

[bobkrech]

Shockie

There is a common misconception that the NAR Model Safety Rocket Code and High Power Rocket Safety Code are the official NAR Model and High Power Rocketry regulations. This is not the case.

At the present time, NAR's policies are based on the NFPA Codes. The NAR Model Rocket Safety Code is an abbreviated subset of the NAR Model Rocket policies and regulations which itself is a superset of NFPA 1122. Similarily The NAR High Power Rocket Safety Code is an abbreviated subset of the NAR High Power Rocket policies and regulations which itself is a superset of NFPA 1127. The NAR S&T Motor Testing and Policy Manual that I have been working on for the past year is a superset of NFPA 1125, more specifically S&T was directed by NARBOT to follow NFPA 1125 explicitly and can only add to it, or make policies in areas not covered by NFPA 1125 such as motor recertifications.

Neither the NAR nor the NFPA Codes are the law in any state as neither organization is empowered to generate and enforce laws. However many states have incoporated the NFPA codes into their regulations which is good, not bad, for hobby rocketry. These NFPA codes are the basis of the NAR (and TRA) policies and regulations, so the incoporation of the NFPA codes into state and local regulations force these authorities to be aligned with hobby rocketry's best interests.

Bob

 

[shockwaveriderz]

hi Bob.


sorry dick: A mind is a terrible thing to be blown up.

I guess I could ask, what if the state and local authorities don't want to be on the same page as the NAR regarding model rocketry regulation.

Should it not be up to the state to opt-in to regulation versus having to opt-out? Isn't that the states right to make that choice for its citizens? Instead of some 3rd party organization most people never heard of?

On the other hand, I can see where "regulation-wise" it would be difficult for the NAR to deal with states and locals, all having diffrent rules and regulations. But that argument presupposes that the state or locals would automatically have a wide variety of pre-existing laws: What if that was not true? But thats not a valid argument either.

What if the states or localities had NO laws or regulations whatsoever?

Why introduce nfpa regulation into an enviornment where they doesn't already pre-exist, if everything has been okay up to that point without any regulation?

This is what the NAR does when it has a state to adopt the NFPA firecodes, even though, the state already has a total, complete exemption written into state law.

What benefit is accured to the end user consumer by applying regulation where there is none previously?

How do I, as a individual model rocketeer stand to benefit from having NFPA regulation applied to my use of model rocketry; instead of allowing the state I live in to just plain EXEMPT it from the state fireworks and explosives laws, with NO other layers of regulation?

I want you and any other readers to imagine a world, where there are NO NFPA regulations governing model rocketry. But each state has simply exempted model rocketry from its fireworks and explosives laws.

But every model rocket kit/motor sold, has a NARMRSC included in it (courtesy of the NAR of course).

I could then fly my model rockets in a non-NFPA regulatory climate, using the NARMRSC as the basis for the way I conduct my model rocket flying activities.

Isn't the NARMRSC really ALL the regulation that is needed to fly model rockets SAFELY?

You can't argue here that NFPA regulations make Model Rocketry any SAFER because the vast majority of people who do model rocketry don't even know the NFPA exists. But if they read the Estes model rocket instruction sheet, they will see the NAR MRSC and they would, I would argue, try to read and follow that.


terry dean
nar 16158

 

[2muchstuff]

At the present time, NAR's policies are based on the NFPA Codes. The NAR Model Rocket Safety Code is an abbreviated subset of the NAR Model Rocket policies and regulations which itself is a superset of NFPA 1122. Similarily The NAR High Power Rocket Safety Code is an abbreviated subset of the NAR High Power Rocket policies and regulations which itself is a superset of NFPA 1127. The NAR S&T Motor Testing and Policy Manual that I have been working on for the past year is a superset of NFPA 1125, more specifically S&T was directed by NARBOT to follow NFPA 1125 explicitly and can only add to it, or make policies in areas not covered by NFPA 1125 such as motor recertifications.

HUH?? Does anyone other than yourself even understand what any of the above means? First it's a subset, than a superset, then a subset, then a superset, then, KABLOOM!!

[snipped]

Wait, I just saw this posted on a different list (hybrids):

"It's from the new NAR Motor Testing Manual that the NAR Board just approved. Manufacturers should have already received a copy and it will soon be on the NAR website."

So, I guess the new motor testing manual is a done deal and we'll all be able to review it any day now. If my club's recent interaction (or more precisely, non-interaction) with NAR HQ is any indication, I'm not going to hold my breath.

I guess I need to email my favorite motor makers and ask them if they've gotten a copy. I wonder what it means if they haven't yet gotten one?


tms

ps: I still don't understand Terry's point to these polls; he completely lost me in his 'explanation' of the whole NFPA issue.

 

[2muchstuff]

There is a common misconception that the NAR Model Safety Rocket Code and High Power Rocket Safety Code are the official NAR Model and High Power Rocketry regulations. This is not the case.

After re-reading this thread trying to make sense of it, I just realized the absurdity of the above statement.

So, you can follow the Model Rocket Safety Code and the HPR Safety Code and still not be in compliance with the ACTUAL NAR safety code, because for reasons that I'm sure will be explained to me by Bob, it would not make sense for the MRSC or the HPRSC to be the official safety code.

I think we need another poll: Who thinks the Safety Codes should be the actual Safety Codes?

I'm sure Bob will tell me that the 'actual' safety codes are too long to be reproduced as the Safety Code that is commonly reproduced. So, isn't NAR doing every one a disservice by referring to the non-safety code as the THE safety code? Shouldn't it be clearer that the Safety Code we know an love is a subset of the REAL safety code, which of course, is a superset of the NFPA regulations. Or something like that.

Is anyone else confused, or is it just me? Someone please point out to me where in the MRSC it says to refer to the REAL Safety Code for the complete NAR rules and regs.

And Bob, BTW, who at NAR is responsible for sending the new NAR S&T Motor Testing guide to motor makers? Any idea on when they were sent out? Who does someone contact if they have are a motor manufacturer and have not yet gotten their copy?


tms

 

[SecretSquirrel]

Having read this thread and the other two poll threads, I'm just going to sit in the corner and drool. I think I got lost about three exits back.

 

[bobkrech]

TMS

Please reread my post. I never said that the NAR Safety Codes weren't the NAR Safety Codes. They are. What I thought was clearly implied is that a 300 to 500 word document can not fully state the NAR Model and High Power Rocketry Policy and Regulations which cover many more items than safety.

The NAR website has a number of documents that you can download if you want more information on NAR policies and regulations. Ted Cochran headed a NAR select committee that conducted an organization wide safety review and authored a massive document on launch safety which may be downloaded there. This study modified parts of the NAR Safety Codes and will be used as the basis for modifications to the NFPA Codes as well on the next update cycle. The NFPA codes are copyrighted and can not be distributed in written form without purchasing them from NFPA however you can got to http//www.nfpa.org and read the codes for free. This is yet another reason why NAR has many more documents than just the safety codes.

The Standard & Testing Committee is a chartered committee of NAR operating under the direction of the NAR President and NARBOT, and the new NAR S&T Motor Testing Manual was commisioned by the NAR President and NARBOT. It is the operating manual of the S&T committee written by and for the professional engineers, scientists, and experienced members who are members of the S&T Committee.

S&T tests and certifies commercial hobby rocket motors using the procedures listed in NFPA 1125, a fact that most folks don't appreciate. S&T policies have always widely distributed to the motor manufacturers, and this testing manual is partly a consolidation of many separate documents. It defines the function of the committee and defines specific chains of command, testing schedules and procedures and testing standards, and addresses certain items not yet included in NFPA 1125.

Draft copies of the new manual were sent to NARBOT and the known and registered motor manufacturers in February by John Lyngdal. The formal adoption of this new document was a subject of the NARBOT meeting at NARCON. I did not attend so I do not know the outcome. The reason that it takes a long time to develop a new technical document is that every has a day job to pay their bills, and there are many revisions and layers of review that must be undertaken in this type of document, literally hundreds of man-hours. While I put together the original framework, major contributions, additions and reviews were conducted by Bill Spadafora, John Lyngdal, Jack Kane, Ed Pattison-Gordon, Trip Barber, Mark Bundick, Ted Cochran, and the rest of the S&T membership prior to submission to NARBOT. Once adopted, the document will be posted on the S&T web pages.

As always, any federally licensed and incoporated motor manufacturer can contact Jack Kane or John Lyngdal for test scheduling.

John J. Kane, Chairman
23 Bungay Road
Mansfield, MA 02048
(508) 339-6439

John Lyngdal, Secretary
17775 SW Janell Court
Beaverton, OR 97006
(503) 649-7371

I hope this response answered your questions.

Bob

 

[shreadvector]

States define and regulate fireworks.

Model Rocket Motors are "fireworks" and if they are not exempted from the normal "fireworks" regulations, they will have to be treated as common fireworks.


And now for the humor:
Is that really so hard to understand? Does this really require another poll or 10,000 word "manifesto"? (Obviously I don't really understand what is going on here, so another 5,000 word explanation should set me straight. But, I won't read it. BUWAHAHAH)

 

[Micromeister]

I'm with you Bob
After wading thur shockie original post, my frist impression was "doesn't shockie know NFPA is the basis for our "code" and that NFPA standards are voted on by every State, city and town as the basic of the various "fire code regulations "enforced" but those bodies?
Humm: I guess many don't.
Unfortunately the answer to the poll is NONE of the above, we need both.

 

[SecretSquirrel]

As always, any federally licensed and incoporated motor manufacturer can contact Jack Kane or John Lyngdal for test scheduling.

But what about sole proprietorships, limited partnerships, limited liability corporations and general partnerships?

 

[falingtrea]

Terry, 6 out of 50 is not a very big number. As a comparison, how many accept the NFPA as code directly? I would say that until the majority of states have this exemption, the NFPA codes will be around and necessary. And I bet these exemptions do not cover high power at all. I also wonder how easy it would have been to get exemptions in 6 states without the exsistance of NFPA1122? I wouldn't be suprised if 1122 was used in some way to get the exemption passed.

Also, from what I understand, MMI lost a lot of business from distributers and hobby stores in the early years because there was no evidence to show that they were safer than fireworks. I am pretty sure Estes's early years were strictly mail order because of this as well.

Now which would be easier? Trying to persuade 50 different legislative bodies of model rocketry's safety, or a group of experts from an organization that already had a good reputation with a majority of those states?

 

[shockwaveriderz]

I'm with you Bob
After wading thur shockie original post, my frist impression was "doesn't shockie know NFPA is the basis for our "code" and that NFPA standards are voted on by every State, city and town as the basic of the various "fire code regulations "enforced" but those bodies?
Humm: I guess many don't.
Unfortunately the answer to the poll is NONE of the above, we need both.

Hi Micro:

the reason, I, shockie, don't know that OUR "code" ( I assume you mean the NAR MRSC) is based upon the NFPA code, is because it simply isn't true, Micro.

It's the other way around: NFPA 41-L the first NFPA 1122 was based upon the then NARMRSC as a starting point.

Long before there was an NFPA 1122 there was a NARMRSC . In fact what most NAR members do not know, there was a time when the NARMRSC actually allowed a person to make their own propellants and motors. Does that shock you?

I also think you are mistaken when you state , "that NFPA standards are voted on by every State, city and town".

Some muncipalities have no fire code whatsoever in place.
And yes some cities and town do "vote" on whether to accept/adopt certain firecodes, but you missed one very important point: Its the states job to adopt a statewide fire code for its citizens; it, is then up to the locals to follow suit.

You missed 1 very important point I was trying to make, and I evidently didn't:

There is a major difference between the state fire marshal 'knowingly" adopting a firecode; its something completely different for a fire code to be adopted, thanks to the fact that a state fire marshal does not read every piece of fine print in such a firecode.


Let me ask a simple, straight question:

If you had a choice between 2 regulatory frameworks:

1. NO NFPA regulation / State exemption/ Fly by the NARMRSC


2. NFPA Regulation / State exemption / Fly by the NARMRSC

why would anybody prefer #2 when the NFPA regulation part isn't needed or wanted by a state?

It seems to me that # 1 would be the best answer:

NO NFPA Regulation/ State exemption / Fly by the NARMRSC.

Somebody explain to me why NFPA regulation is better than NO NFPA regulation of model rocketry?


From 1957-1968 There was NO NFPA Model Rocketry Fire Code. Model Rocketry did just fine thank you. Sure some towns actually banned model rocketry (which they can still do thru a simple ordinance). In some states model rocketry was exempted from the fireworks laws; in other states, model rocketry was allowed because the state or local fire marshal's saw that that model rockets weren't fireworks. (actually most fire marshal's did think model rockets were a form of fireworks, but because they had a recovery system, electrical ignition, reuseability, it just moved model rockets into the cataegory of a safe and sane firework. )

well into the 70's and 80's and 90's a majority of states did not adopt NFPA 1122. Ask yourself why? Its actually pretty simple: most state and local fire marshals' saw NFPA 1122 as a form of regulation that they would never be able to enforce. So their thinking, was, why adopt a fire code that can't be enforced? What good is it? Otherwise, its just another regulation for the sake of regulation.

So, since the state fire marshal's weren't cooperating with the NAR master plan to have NFPA 1122 adopted nationwide, the NAR and the NFPA came upon a simple solution:

We will just place adoption of the rocketry firecodes into another firecode that we know states will willingly adopt.

They knew and know that a typical fire official is a very busy person, and doesn't have time to read a document that has literally 100's if not thousand's of pages of mind-numbing regulations.

And so thats what the NAR and the NFPA did. They took the choice away from your state fire marshal and legislature, and made the choice for YOU. In other words, they took the responsibility for the regulation of modle rocketry out of the hands of the state fire marshal and placed it squarely in the hands of the NFPA. Even when state fire marsha;s did not want the regulation.

Pretty sneaky huh?

Even in states that had long exempted model rocketry from their state fireworks and explosives laws, the NAR/NFPA succeeded in getting all states to adopt the Model rocket firecode, by stealth.

Somebody please answer me the question why those states needed NFPA 1122 to regulate model rocketry? When the states had already decided that as far as they were concerned, model rocketry needed no regulation hence the exemptions?


Here's my bottom line:

Model Rocketry is NO safer because of NFPA 1122. Model rocketry would still have its stellar safty record, even if NFPA 1122 was never implemented. In fact, for most of the 50 year history of model rocketry in this country, most states and localities had no regulation whatsoever concerning model rockets. In essence, they model rocketry was totally and completely unregulated.

The fact that for most of these 50 years, there was no regulation indicates to me that Model Rocketry is inherently a safe activity: If a person simply reads and follows the NARMRSC they will be as safe flying model rockets as they would be flying in a state that has NFPA 1122 on the books.

terry dean
nar 16158

 

[shreadvector]

States define and regulate fireworks.

Model Rocket Motors are "fireworks" and if they are not exempted from the normal "fireworks" regulations, they will have to be treated as common fireworks.


And now for the humor:
Is that really so hard to understand? Does this really require another poll or 10,000 word "manifesto"? (Obviously I don't really understand what is going on here, so another 5,000 word explanation should set me straight. But, I won't read it. BUWAHAHAH)

maybe I need yet another poll to ask: "Who else did not read that last "Manifesto" ? "

 

[shockwaveriderz]

maybe I need yet another poll to ask: "Who else did not read that last "Manifesto" ? "

maybe if you actually took the time to read it, you might learn something Fred. Its quite easy to denigrate me and what I am saying by making fun and light of it. and using catch phrases and buzzwords like "manifesto"...

bottomline:

the NAR is pro-regulation, contrary to whatever it says.
the NAR's stance is that "regulation is good for hobby rocketry".

terry dean
nar 16158

 

[WillMarchant]

Sorry, I didn't realize that in 2008 the AMA discarded their model rocketry safety code and now tells AMA members to abide by the NAR model rocket safety code...

 

[Ted Cochran]

Here's my bottom line:

Model Rocketry is NO safer because of NFPA 1122. Model rocketry would still have its stellar safty record, even if NFPA 1122 was never implemented. In fact, for most of the 50 year history of model rocketry in this country, most states and localities had no regulation whatsoever concerning model rockets. In essence, they model rocketry was totally and completely unregulated.

NFPA 1122 implements NAR's MRSC, essentially; and NAR works hard to keep the two congruent.

If there are no regulations whatsoever concerning model rockets, then people flying model rockets are at the mercy of local authorities, who can, and have, hassled them based on laws against fireworks, disturbing the peace, whatever they want to charge.

"I'm flying in full compliance with state fire regulations."

"OK, then, have fun!"

Let me turn your question around: What specifically in NFPA 1122 do you wish to be allowed the freedom to violate? Because there are lots of ways to do that, too--including, especially, getting permission from your fire marshal. If it violates the MRSC, you need to get permission from the BoT, but there's a policy for doing that.

There is a huge difference between laws and regulations. Regulations, especially fire regulations, usually come into play when something goes horribly wrong. If it goes wrong when you're in compliance with regulations, you're way better off than if you say, "There's no law against it!"

 

[shockwaveriderz]

Bob:

"At the present time, NAR's policies are based on the NFPA Codes."

Why is that Bob? wouldn't it better for the NAR to have their own set of policies based upon what is best for its members?


"Neither the NAR nor the NFPA Codes are the law in any state as neither organization is empowered to generate and enforce laws."

This simply is not true. The NFPA fire codes are LAW in the states and localities were they are adopted.

If you violate a fire code, you can be cited and fined.

" However many states have incoporated the NFPA codes into their regulations which is good, not bad, for hobby rocketry."

Please elaborate on NOT how NFPA 1122 has been "GOOD" for "hobby rocketry" but how has it been good for Model Rocketry. Has NFPA 1122 made model rocketry any safer? Isn't THAT what NFPA 1122 is suposed to be about?


"These NFPA codes are the basis of the NAR (and TRA) policies and regulations, so the incoporation of the NFPA codes into state and local regulations force these authorities to be aligned with hobby rocketry's best interests."


Notice the use of the word FORCE above? The NAR/NFPA forces states to adopt fire codes regulating model rocketry so the NAR/NFPA will all be on the same page.


For most of the 50 year history of model rocketry in this country, most states did not adopt NFPA 1122; and the NAR and model rocketry seemed to function just fine.

What if a state or locality didn't want to be "on the same page" as the NAR/NFPA? What if they didn't want to be aligned with the stars and the NAR/NFPA? Isn't/wasn't that the right of each of these states to make that choice for themselves, without having a fire code rammed down their thorats by stealthy means, so they could be as one with the NAR/NFPA ?

Bob, you know what this sounds like to me? It sounds like the NAR/NFPA is the "BORG" Collective and it has been slowly but surely assimilating every state . Resistence is futile indeed!



terry dean
nar 16158

 

[falingtrea]

Terry, have you ever heard of self regulation??? Seems to me that is what the NFPA is doing for the hobby. And a lot better job of self regulating than the computer/console gaming is doing. As for the NAR doing self regulation, which do you think would have worked back then?? Regulations from an organization that was only a few years old at the time or an organization with at least a 50 year history of standards work?? Also, the states were not the only organizations we had to deal with. Don't forget CPSC and DOT. Without the NFPA standards I bet it would have been a lot harder to get the exemptions we have now.

 

[KermieD]

I have a question:

Is there a practical application and/or point of action that is being taken as a result of this discussion?

 

[Ted Cochran]

TMS

Ted Cochran headed a NAR select committee that conducted an organization wide safety review and authored a massive document on launch safety which may be downloaded there. This study modified parts of the NAR Safety Codes and will be used as the basis for modifications to the NFPA Codes as well on the next update cycle.
Bob

Just to correct a couple of points. Jay Apt headed the special committee. It recommended a bunch of safety code changes, some of which were modified after various discussion with interested parties. Among the recommendations were the establishment of a permanent committee on safety, which was done, and which I lead.

The safety code changes were adopted in July 2006 and incorporated into NFPA 1127 that just came out in January 2008. I don't know of any additional safety code or NFPA changes being discussed.


I think the NFPA process is pretty bureaucratic and slow, but it is at least a public and open process. Without NFPA, rocketry codes would be different everywhere. And, as I said earlier having "no rocketry regulations" is not at all the same as "freedom to fly"--whatever that means. In this day and age, having "no regulations" means authorities will apply whatever they wish. Just as a personal example, I was denied permission to have a magazine in Minneapolis by a Fire Marshal who applied regulations on explosives. I won via an appeal to the State Fire Marshal's office only because of NFPA 1127--even though it wasn't adopted in Minnesota at that time--because it was an official NFPA code that directly applied to my situation, and MN code had a provision that allowed unadopted codes to be used in such cases.

Finally, NFPA 1122 and NFPA 1127, even when adopted, generally do not prohibit practices that do not comply with them. Had my appeal been lost, I could still have had a magazine; I'd have just had to adhere to explosives storage regulations, and get a home out in the country.

As another example, you can make your own model rocket motors if you want--it's just not compliant with NFPA 1122 (or the NAR safety code). So instead, you have to figure out what you DO have to comply with (usually some combination of explosives manufacturing regulations, public nuisance laws, non-NAR insurance, non-NAR ranges, etc). It's a lot more work, but it isn't illegal, so long as you identify and comply with every provision the AHJ(s) may require.

Hope that helps,

--tc

 

[bobkrech]

Thanks Ted for correcting those points.

Bob

 

[Trip Barber]

TMS


Draft copies of the new manual were sent to NARBOT and the known and registered motor manufacturers in February by John Lyngdal. The formal adoption of this new document was a subject of the NARBOT meeting at NARCON. I did not attend so I do not know the outcome. The reason that it takes a long time to develop a new technical document is that every has a day job to pay their bills, and there are many revisions and layers of review that must be undertaken in this type of document, literally hundreds of man-hours. While I put together the original framework, major contributions, additions and reviews were conducted by Bill Spadafora, John Lyngdal, Jack Kane, Ed Pattison-Gordon, Trip Barber, Mark Bundick, Ted Cochran, and the rest of the S&T membership prior to submission to NARBOT. Once adopted, the document will be posted on the S&T web pages.

Bob

In response to Bob's comment above, the new NAR S&T procedural manual is approved by the NAR Board of Trustees and went into effect as of March 1, 2008. It has been distributed to TMT and the CAR, and to motor manufacturers, who are the people affected by it. It will be posted on the NAR website soon for general information of the membership.

Trip Barber
NAR 4322
NAR VP

 

[Micromeister]

Terry:
None of that changes the fact that we do indeed need regulatory oversight on a National level, so that we don't (for the most part) have to fight each and every little city, town or berg legislature with concern about Model rocketry.
In my business I have to deal with these folks on a regular basis and it's NO picnic!
As a model rocket flyer, I can't tell you the number of times I've been stopped by a "local policemen"... HEY do you have a licence to do that..
I simply pull out my NAR card and answwer why yes I do, and go on to explain how our safety code is a product of the allience between the NFPA and the NAR which have HAPPILY seperated us from the fireworks folks for generartions now.
Your messing for some reason with something you shouldn't be. The NFPA/NAR regulations as Ted mentions have done wonders for your credibililty with these state, city and town lawmakes, and HAVE helped immensely in keeping model rocketry out of the lawmakers hands for these last 50 years your complaining about.
Has the NFPA alone made Model rocketry safer...NO but they sure as HECK have helped maintain it's avaialbility to the masses by keeping local lawmakers from enacting regulations that prohibit our hobby, which is where your so WAY off base my friend

What's your REAL reason for posting this poll?

Still the answer remains that same... NONE of the Above; WE NEED Both the NARMRSC and NFPA regs.

 

[2muchstuff]

The NAR website has a number of documents that you can download if you want more information on NAR policies and regulations...
...Draft copies of the new manual were sent to NARBOT and the known and registered motor manufacturers in February by John Lyngdal.

As always, any federally licensed and incoporated motor manufacturer can contact Jack Kane or John Lyngdal for test scheduling.

Then why doesn't the MRSC say to consult NAR for a complete reading? Any 'reasonable' person reading the MRSC as listed in most model rocket kits would get the impression that it's a complete code. There is no mention that there is a more complete code to be had. To expect newcomers to the hobby to figure that out on their own is just giving them an excuse for ignorance.

On the updated motor testing policies, I talked with one motor maker who (as I understood it) said not only did he not get a copy of the new testing standards, but that TWO previous requests for such a document frrom NAR, sent via certified letter, went unanswered! And yes, he is a known and registered motor maker.

So, what does it mean that requests have gone unaswered and that a motor maker did not get an updated copy? Being 'forgotten' is one thing, but if requests are going unaswered and motor makers are being actively 'ignored', that sure sounds like a disservice to the very folks that NAR should be trying to help. We do pay dues to NAR to help promote the hobby, and presumably, to help those trying to offer products to NAR members.

Is there a list somewhere of the makers who NAR has on file? Any reason why a maker would be ignored or left off the list?

I'm on spring break so I haven't had a chance to hear from any other makers, but I'll post whatever I hear back from them.


tms

 

[bobkrech]

Then why doesn't the MRSC say to consult NAR for a complete reading? Any 'reasonable' person reading the MRSC as listed in most model rocket kits would get the impression that it's a complete code. There is no mention that there is a more complete code to be had. To expect newcomers to the hobby to figure that out on their own is just giving them an excuse for ignorance.

With apologies to the other readers...

TMS

In post #8 of this thread I asked you to reread post #3 of this thread. Perhaps my reponse was not clear enough or you don't understand the meaning of a superset and a subset so here's a much more detailed and documented response.

NAR policies and regulations <--- NFPA 1122 ---> NAR Model Rocket Safety Code

NAR https://www.nar.org is a non-profit coporation that has by-laws https://www.nar.org/cabinet/bylaws.pdf that describe its purpose, organization, function, and membership policies. Organiations have other regulations and policies that are ancillary to the by-lays and many of the NAR policies are posted here https://www.nar.org/cabinet/index.shtml If you need further information on NAR you can find a contact list of all NAR officers, BOT members, and Committee Chairmen here https://www.nar.org/NARadmin.html

Article XI, Section 4 of the by-laws states "The Standards and Testing Committee shall have as its duties the establishment and revision of the standards and regulations of the Association, and the testing and certification of equipment as called out in the standards and regulations of the Association."

The NAR S&T is accepted as competent authority and more recently as an authority having jurisdiction by NFPA. https://www.nfpa.org NAR officials sit as members on 3 NFPA committees: 1122, 1125, and 1127: together with TRA officials https://www.tripoli.org , the motor manufactures and other pyrotechnic manufacturers, and Representatives of interested branches of government and the public sector. NAR S&T certifications are accepted by the Consumer Products Safety Commission that allows the sale of certified model rocket motors to the general public.

NFPA 1122 is one product of this association and it legitimizes the commercial sale of model rocket motors to the public in the 50 states. S&T has recommended that it become the standard for model rocketry in NAR and it has been for many years. The current NAR Model Rocket Safety Code https://www.nar.org/cabinet/MRSafetyCode.pdf has evolved over the past 50 years and is currently a condensed summary of the safe operating procedures as defined in NFPA 1122 and NAR policies, and is inculded with most, if not all, model rocket motors and kits.

I hope this is clear enough.

On the updated motor testing policies, I talked with one motor maker who (as I understood it) said not only did he not get a copy of the new testing standards, but that TWO previous requests for such a document frrom NAR, sent via certified letter, went unanswered! And yes, he is a known and registered motor maker.

So, what does it mean that requests have gone unaswered and that a motor maker did not get an updated copy? Being 'forgotten' is one thing, but if requests are going unaswered and motor makers are being actively 'ignored', that sure sounds like a disservice to the very folks that NAR should be trying to help. We do pay dues to NAR to help promote the hobby, and presumably, to help those trying to offer products to NAR members.

Is there a list somewhere of the makers who NAR has on file? Any reason why a maker would be ignored or left off the list?

I'm on spring break so I haven't had a chance to hear from any other makers, but I'll post whatever I hear back from them.

tms

From post #23 of this thread:

In response to Bob's comment above, the new NAR S&T procedural manual is approved by the NAR Board of Trustees and went into effect as of March 1, 2008. It has been distributed to TMT and the CAR, and to motor manufacturers, who are the people affected by it. It will be posted on the NAR website soon for general information of the membership.

Trip Barber

The list of NAR list of motor manufacturers consists of: motor manufacturers who have submitted motors for NAR certification and are still currently in business, motor manufacturers who manufacturer motors currently certified by TMT and CAR.

NAR and S&T adopted NFPA 1125 as the motor testing standards for NAR certified motors years ago. All motor manfacturers are expected to have a copy of NFPA 1125 and their motors are required to be in full compliance with NFPA 1125 before they are submitted for certification.

NFPA 1125-3.3.7 provides the definition of a motor manufacturer. Just saying you are a motor manufacturer does not make you one. Perhaps you friend has failed to comply with a S&T request to produce proof of currently valid BATFE explosives manufacturer permit and/or failed to provide evidence that his propellants and motors have valid and current EX numbers to legal transportation and sales. BATFE will promptly confirm if a BATFE permit number is valid and DOT maintains an up-to-date list of a EX numbers on-line so verification is simple. Several motor manufacturers have complex coporate structures however they have all submitted a paper trail to verify that their DBA is owned by the corporation registered with BATFE and DOT. Perhaps you friend has refused to provide this information to S&T. If he has truely been ignored which I doubt, I suggest that he sends a certified letter to Mark Bundick which will elicit and immediate responsed.

The new S&T Committee Motor Testing Manual places all of the S&T testing requirements and policies in one document for the first time. It does not repeat the wording of 1125 but does explain the procedural requirements for a manufacture to submit his motors for certification. They are given below.

Section 2 &#8211; Application for Certification Testing

2.1 Application Submission

Commercial rocket motor manufacturers who wish to have motors tested for NAR certification must make written application to the S&T Chairperson by mail, courier, fax or e-mail or other means. The application must include the following information and any other that may be deemed appropriate:

2.1.1 Full business name and address of the manufacturer of the motor.

2.1.2 Name of applicant. Applicant must be an authorized representative of the manufacturer; motors may not be submitted for certification testing by other parties, except per 2.1.3 below.

2.1.3 In the case of foreign manufacturers wishing to have motors tested for NAR certification to support consumer sale in the U.S., the applicant may be an agent of the manufacturer such as an importer or dealer, in which case the application must include a letter of permission from the manufacturer indicating approval of the application being made on their behalf.

2.1.4 A complete list and description of the motors to be tested, including all delay times or other variations requiring separate test. Physical configuration such as length and diameter must be included to ensure that compatible test fixtures are available for static firing. Performance data including (at minimum) total impulse, maximum thrust, burn time, and delay time must be included and must be of reasonable accuracy in order to assess test equipment compatibility. If a manufacturer is not able to provide basic information on the delivered performance of a motor system offered for testing, S&T may refuse testing until this information is provided. Otherwise, S&T test equipment may be subjected to unknown stresses and damage, and test personnel may be put at risk.

2.1.5 If the motors to be tested require any special provisions, such as proprietary ground support equipment or vertical test fixtures, a complete description of the equipment and other provisions required to complete the tests. Supply of or cost of any special provisions required for S&T testing is the responsibility of the manufacturer unless otherwise decided by the S&T Chairperson.

2.1.6 Written proof as required by NFPA 1125 that any pyrotechnic or low explosive materials in the motors to be tested have been manufactured or imported in compliance with the licensing requirements of the Bureau or Alcohol, Tobacco, Firearms, and Explosives (BATFE), and that the motors themselves or the appropriate materials in them have been classified for transportation the US Department of Transportation (DOT) as UN 1.3 or 1.4 explosives or 4.1 flammable solids. This information may include but is not limited to the following: a copy of a BATFE license for explosives manufacture; and either proof of DOT-approved UN classification of the compositions or devices, or if this classification is still pending a letter of permission issued by the DOT for the purposes of one-time transport for testing of new devices.

2.3 Scheduling Test Sessions

Upon receipt and approval of a written application for testing, the S&T Chairperson will, in cooperation with the manufacturer and committee members, assign a testing location and schedule a test session of sufficient duration at the earliest possible date. The S&T Chairperson will advise the manufacturer in writing of the following:

Fees associated with the certification testing
The quantity of each motor type required
The address for shipment of the test articles
Proposed test date and location

2.4 Shipping of Motors for Testing

Motors must be legally shipped to the designated test site in a manner that will ensure arrival a minimum of seven days before the scheduled test date. Exceptions for later arrival may be made by agreement with the S&T Chairperson. Upon receipt of the test motor shipment the supervisor of the receiving test site (S&T Chairperson or Regional Subcommittee Chairperson, as appropriate) will advise the manufacturer promptly. Any damage, losses or omissions will be reported immediately to the manufacturer for remedy. The manufacturer will include with the shipment a complete list of all items included, and will clearly label or mark all items for identification.

2.5 Packaging of Motors for Testing

Motors to be tested must be packaged in the form in which they are to be offered to consumers, including instructions for use, igniters, etc. in order for the S&T to assess the suitability of the product for general consumer use. Exceptions to this rule may be made at the discretion of the S&T chairperson, for example if only a draft copy of the instructions is available as of the testing date.

2.6 Reservation of Right of Refusal

The S&T Chairperson reserves the right to refuse for certification testing any motor that, in the opinion of the chairperson or regional test director is flawed, damaged, of obvious poor design, or is otherwise unsafe or unsuitable for testing and that could present unreasonable hazard to the test committee personnel and equipment or to the membership of the NAR.

Section 4 &#8211; General Submission Requirements

4.1 Motor Construction

All motors submitted for S&T initial-certification testing must be accompanied by manufacturer documentation of how they were designed and constructed as specified in NFPA 1125 such that:

4.1.1 In the event of a catastrophic failure, motor fragments will be projected predominantly in a longitudinal direction relative to the motor, and that no fragments will project further than:
&#8226; 3m (10 feet) for motors under 30 Ns total impulse
&#8226; 6m (20 feet) for motors of 30Ns to 160 Ns total impulse
&#8226; For high power motors, the distances prescribed in NFPA 1125 Table 7.4.3

4.1.2 For metal-casing reloadable motors, the casing rupture pressure is at least twice the peak pressure normally expected to be developed by the reloadable motor system to be tested in that casing.

4.2 Motor Instructions

All motors submitted for S&T testing shall include complete instructions for assembly and use meeting the requirements of NFPA 1125. Motors will not be certified unless suitable and complete instructions for safe use are provided. Omissions or errors will be reported to the manufacturer for remedy prior to certification, and S&T will not be responsible for any failed tests or lost data caused by any problems related to the instructions provided.

4.3 Production Date Codes

All motors submitted for testing and subsequently offered for sale must have date of manufacture or other equivalent coding imprinted on the casing and/or reload package as required by NFPA 1125.

4.4 Motor Igniters

All motors submitted for testing must include the igniter that will be offered by the manufacturer for said motor type if any. If packaged separately from the motors or reload kits, the manufacturer must clearly identify which igniter is to be used with a particular motor type. If igniters are supplied with the motors, a minimum of one extra igniter per test group must be included to address instances where there is an igniter or motor ignition failure occurs.

4.4.1 In the event that the motors are to be offered for sale without a corresponding igniter included in the motor package or offered separately by the manufacturer, the manufacturer must either supply suitable igniters for the test session, or reimburse the S&T for the cost of acquiring them as per the recommendation of the manufacturer. In cases where the manufacturer does not supply a suitable igniter with the product, S&T assumes no responsibility for delays in testing, test data deviation, loss of test data or any other anomaly caused by problems associated with motor ignition.

The full text of the manual will be on-line shortly for all to read once a NAR website posting bug is fixed. Ed. Note: It is posted here https://www.nar.org/SandT/docs/

Again to the other readers, my apology for the excessively (for most) long response.

Bob

 

[matthew]

4.4 Motor Igniters

All motors submitted for testing must include the igniter that will be offered by the manufacturer for said motor type if any. If packaged separately from the motors or reload kits, the manufacturer must clearly identify which igniter is to be used with a particular motor type. If igniters are supplied with the motors, a minimum of one extra igniter per test group must be included to address instances where there is an igniter or motor ignition failure occurs.

4.4.1 In the event that the motors are to be offered for sale without a corresponding igniter included in the motor package or offered separately by the manufacturer, the manufacturer must either supply suitable igniters for the test session, or reimburse the S&T for the cost of acquiring them as per the recommendation of the manufacturer. In cases where the manufacturer does not supply a suitable igniter with the product, S&T assumes no responsibility for delays in testing, test data deviation, loss of test data or any other anomaly caused by problems associated with motor ignition.

Does this mean that igniters are not part of the certified product?

 

[SecretSquirrel]

If he has truely been ignored which I doubt, I suggest that he sends a certified letter to Mark Bundick which will elicit and immediate responsed.

I can confirm the account is true. 2 certified letters sent approx 30 days apart to the address listed on the NAR web site. I can also confirm that Marie signed for at least one of those letters.

 

[shockwaveriderz]

Terry, 6 out of 50 is not a very big number. As a comparison, how many accept the NFPA as code directly? I would say that until the majority of states have this exemption, the NFPA codes will be around and necessary. And I bet these exemptions do not cover high power at all. I also wonder how easy it would have been to get exemptions in 6 states without the exsistance of NFPA1122? I wouldn't be suprised if 1122 was used in some way to get the exemption passed.

Also, from what I understand, MMI lost a lot of business from distributers and hobby stores in the early years because there was no evidence to show that they were safer than fireworks. I am pretty sure Estes's early years were strictly mail order because of this as well.

Now which would be easier? Trying to persuade 50 different legislative bodies of model rocketry's safety, or a group of experts from an organization that already had a good reputation with a majority of those states?

Tim:

as I noted, that 6 was only a cursory 15 minute google.... If I took the time to look at all 50 states, it might take me a while. In fact I am now trying to put together a master listing of which states had model rocketry exemptions prior to any NFPA adoption. I am also trying to put together a listing which shows which states adopted NFPA 1122 and when.

From a historical viewpoint, yes, I'm sure that some MMI product was indeed pulled from the shelves; in fact I know it was done by certain states like MASS where the state fire marshal sent a notice to all fire chiefs in his state, reminding them that the "Rock-A-Chute" violated MASS fire laws. BUT by 1967/68 model rocketry had essentially succeeded in the marketplace.

The "genesis" of the NFPA 41L began back in approx 1964; the NFPA Standards Council for reasons only known to them determined that Model Rocketry needed a NFPA "firecode" to distinguish it from fireworks and therefore it also needed to be regulated.

The person that G. Harry Stine gives the most credit for this effort was a Carroll E. Shaw who was the Connecticut State Fire Marshal and a NFPA member in good standing.

I don't know (yet) who approached who first: did G. Harry Stine approach Mr. Carroll or did Mr. Carroll approach G. Harry Stine? It doesn't really matter as it is known that as early as 1961, the enabling legislation for the eventual to come Connecticut Model Rocket Code which would become Connectcut law in 1963, the 1st state in the union with a model rocket law. Of Course, G. Harry Stine lived and worked in Connecticut and the NAR was HQ'ed there also during this time frame.

In 1962 G. Harry Stine instructed the then NAR Counsel to draw up a Uniform Model Rocket Act document so that interested Senior members of the NAR would have some guidelines on how to get state laws passed in favor of model rocketry.


Anyway, the major point still remains that for most of the 50 yr history of Model Rocketry, NO NFPA regulations were in effect in the majority of states in this county and Model Rocketry did just fine. This is a fact that nobody can dispute.

The argument that a state or local entity back then could ban model rocketry is still true today; in spite of any NFPA regulations. In 1969, a man was accused in NY State of selling model rockets in violation of NY state Fireworks laws. He won his case. In 1970 Defiance ,OH completely banned model rocketry. The new NFPA regualtions didn't seem to help in these two cases, and cases.
In fact, as G. Harry noted, it would take a long time to get everybody to adopt these new regulations. AND he was correct.
In fact it was taking a lot longer than he or for that matter anybody realized. For whatever reasons, most state fire marshal's never showed much interest in adopting NFPA 1122, and thats why the NFPA Technical Committee and the NAR NFPA Liason decided that the best way to get NFPA 1122 adopted was to surreptitiously insert adopting code into other NFPA firecodes that they knew would be adopted readily by state fire marshal's like NFPA 1. IT was this code insertion into NFPA 1 and similar code into the competing IFC that eventualy resulyed in NFPA 1122 being adopted in something like 48 states.

If the enabling code had not been placed in NFPA 1 and the latest IFC, its highly likely that the adoption rate of NFPA 1122 would have stayed were it was at. THis enabling code was placed in NFPA 1 and the IFC sometime back in the 1990's.

So instead of having 48/49 states adopting NFPA 1122 we might still be back at < 30 states. Remember, 20 states have adopted NFPA 1 which adopts not only NFPA 1122 but also NFPA 1125 and 1127.

So you argument about dealing with 50 different people is only valid to a point. And it seemed to be working find that way for quite some time.

If a local city council wanted to ban model rocketry today it would be a relatively simple and easy process to accomplish in spite of any state NFPA regulations, as cities and localities have always had the power to regulate themselves stricter than state law generally would allow for.

The major point here is that having a state adopt a NFPA fire code is no protection from model rocketry being negatively impacted.

hope this answers your inquiries

terry dean
nar 16158

 

[billspad]

In response to Bob's comment above, the new NAR S&T procedural manual is approved by the NAR Board of Trustees and went into effect as of March 1, 2008. It has been distributed to TMT and the CAR, and to motor manufacturers, who are the people affected by it. It will be posted on the NAR website soon for general information of the membership.

Trip Barber
NAR 4322
NAR VP

The links to this page haven't been set up yet but you can get to that document from here:

https://www.nar.org/SandT/docs/


and before somebody points out some of the page numbers in the table of contents are wrong, we know and they'll be fixed soon.