Effect of HSA on Standard Pro38's

Effect of HSA on Standard Pro38's

Post by Mark Knap » Thu, 17 Apr 2003 20:09:47



Hi,
     I was wondering if anybody could shed some intelligent light on the
standard Pro38's and if they will also be exempted since they are not APCP
and listed as 62.5 grams. Again no philosophy just respond with real answers
as best as we know them.  Thanks

Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by David Schult » Thu, 17 Apr 2003 08:30:36


 From the MSDS on the Pro38 site:

"These articles contain propellant and delay charge modules which
consist primarily of ammonium perchlorate (NH4ClO4) dispersed in
synthetic ***."

Sounds like APCP to me.

Classified as UN0351, Articles, Explosives, N.O.S.

Quote:

> Hi,
>      I was wondering if anybody could shed some intelligent light on the
> standard Pro38's and if they will also be exempted since they are not APCP
> and listed as 62.5 grams. Again no philosophy just respond with real answers
> as best as we know them.  Thanks

> Mark Knapp


 
 
 

Effect of HSA on Standard Pro38's

Post by Mark Knap » Thu, 17 Apr 2003 21:05:55


Hi,
    Thanks for pointing this out to me. I didn't relize they had APCP in
them because most of their pages list it as a Thermoplastic Propellant which
I thought was different . What about the 62.5 gram's listed for the Classic
Pro38 wouldn't this then make them exempt from HSA or as far as the Pro38
goes what does this really mean when they use it .  Thanks

Mark Knapp


Quote:
> From the MSDS on the Pro38 site:

> "These articles contain propellant and delay charge modules which
> consist primarily of ammonium perchlorate (NH4ClO4) dispersed in
> synthetic ***."

> Sounds like APCP to me.

> Classified as UN0351, Articles, Explosives, N.O.S.


> > Hi,
> >      I was wondering if anybody could shed some intelligent light on the
> > standard Pro38's and if they will also be exempted since they are not
APCP
> > and listed as 62.5 grams. Again no philosophy just respond with real
answers
> > as best as we know them.  Thanks

> > Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by David Schult » Thu, 17 Apr 2003 09:47:56


As far as I can tell, the exemption status of the Pro38's is fuzzy.

The original ATF exemption was for motors classified by the DOT as Class
C "Toy Propellant Devices". This exemption became problematic in the
early 90's when the DOT revamped their regulations to bring them into
line with the United Nations hazardous materials designations. As part
of that, the toy propellant device definition vanished. The ATF
exemption vanished completely (by mistake?) in 1998. The ATF has been
saying since 1994 or so that only motors with less than 62.5 gram
assembled weight are exempt. This is a lie because that rule has never
(until now) been through the required regulatory process. Right now
there are only two defensible positions: 1) No rocket motors are exempt.
Even Estes. 2) Class C toy propellant devices are exempt.

Aerotech has documents from the DOT showing designations for their "Easy
Access" reloads as Class C "toy propellant devices" so they are exempt.
Aerotech has to jump through "inner packaging" hoops to get them a 1.4C
classification.

Pro38's do not have a designation as a toy propellant device by the DOT.
Pro38's are shipped as a fully assembled (almost) motor. Just slide into
a motor tube. How they got a 1.4C classification for this I do not know.

You could make a case that Pro38's are regulated now.

Oddly, Pro54's are classified as 1.4C as well but at least one vendor
requires a LEUP for purchase.

Quote:

> Hi,
>     Thanks for pointing this out to me. I didn't relize they had APCP in
> them because most of their pages list it as a Thermoplastic Propellant which
> I thought was different . What about the 62.5 gram's listed for the Classic
> Pro38 wouldn't this then make them exempt from HSA or as far as the Pro38
> goes what does this really mean when they use it .  Thanks

> Mark Knapp



>>From the MSDS on the Pro38 site:

>>"These articles contain propellant and delay charge modules which
>>consist primarily of ammonium perchlorate (NH4ClO4) dispersed in
>>synthetic ***."

>>Sounds like APCP to me.

>>Classified as UN0351, Articles, Explosives, N.O.S.


>>>Hi,
>>>     I was wondering if anybody could shed some intelligent light on the
>>>standard Pro38's and if they will also be exempted since they are not

> APCP

>>>and listed as 62.5 grams. Again no philosophy just respond with real

> answers

>>>as best as we know them.  Thanks

>>>Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by Jerry Irvin » Thu, 17 Apr 2003 09:56:53




Quote:
> Hi,
>     Thanks for pointing this out to me. I didn't relize they had APCP in
> them because most of their pages list it as a Thermoplastic Propellant which

That refers to the binder which can be repurposed to an extrusion
process if demand warrants.  Anyone know if it has yet?

Jerry

Quote:
> I thought was different . What about the 62.5 gram's listed for the Classic
> Pro38 wouldn't this then make them exempt from HSA or as far as the Pro38
> goes what does this really mean when they use it .  Thanks

> Mark Knapp

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA

Please bring common sense back to rocketry administration.
Produce then publish.  http://www.usrockets.com
 
 
 

Effect of HSA on Standard Pro38's

Post by Jerry Irvin » Thu, 17 Apr 2003 10:04:30




Quote:
> As far as I can tell, the exemption status of the Pro38's is fuzzy.

> The original ATF exemption was for motors classified by the DOT as Class
> C "Toy Propellant Devices". This exemption became problematic in the
> early 90's when the DOT revamped their regulations to bring them into
> line with the United Nations hazardous materials designations. As part
> of that, the toy propellant device definition vanished. The ATF

Almost:

Provisions for using old classifications of explosives 49 CFR 173.53

Where the classification system in effect prior to January 1, 1991, is
referenced in State or local laws, ordinances or regulations not
pertaining to
the transportation of hazardous materials, the following table may be
used to
compare old and new hazard class names: Current Classification Class
name prior
to Jan 1, 1991
Division 1.1 Class A explosives
Division 1.2 Class A or Class B explosives
Division 1.3 Class B explosives
Division 1.4 Class C explosives
Division 1.5 Blasting Agents
Division 1.6 No applicable hazard class

Quote:
> exemption vanished completely (by mistake?) in 1998. The ATF has been

ATF does NOTHING by mistake.  They were the FIRST to see the above
language translating ALL 1.4.anything to exemption by reference.

Their reply?

A reg change to list a narrow set of UN numbers.

Let's fix that in THIS NPRM 968 comment period as I have stated before
and here is your ammunition.  You're welcome.

Quote:
> saying since 1994 or so that only motors with less than 62.5 gram
> assembled weight are exempt.

NOT by law or even writren rule. Only by "intention to change the rule
in the future".

Quote:
> This is a lie because that rule has never
> (until now) been through the required regulatory process.

Exactly right and that FACT should be brought up in NPRM 968 in a way to
ask WHO said this (actual name), who approved its restatement (actual
names), who published it (actual names) and what penalties exist as THEY
would persue for fraud on explosives laws under color of authority.  Ask
the hard questions.  The mo-fo's deserve it.

Quote:
> Right now
> there are only two defensible positions: 1) No rocket motors are exempt.
> Even Estes. 2) Class C toy propellant devices are exempt.

> Aerotech has documents from the DOT showing designations for their "Easy
> Access" reloads as Class C "toy propellant devices" so they are exempt.
> Aerotech has to jump through "inner packaging" hoops to get them a 1.4C
> classification.

> Pro38's do not have a designation as a toy propellant device by the DOT.
> Pro38's are shipped as a fully assembled (almost) motor. Just slide into
> a motor tube. How they got a 1.4C classification for this I do not know.

Expensive tests errortech had no inclination or cash to perform.

Quote:

> You could make a case that Pro38's are regulated now.

> Oddly, Pro54's are classified as 1.4C as well but at least one vendor
> requires a LEUP for purchase.

That is a STUPID voluntary effort that should be RESCINDED immediately.

Jerry

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA

Please bring common sense back to rocketry administration.
Produce then publish.  http://www.usrockets.com

 
 
 

Effect of HSA on Standard Pro38's

Post by RayDunak » Thu, 17 Apr 2003 10:38:35


<<  I was wondering if anybody could shed some intelligent light on the
standard Pro38's and if they will also be exempted since they are not APCP and
listed as 62.5 grams. >>

They actually are APCP, regardless of the fact that they use a different type
of binder. So no, they will not be exempted unless we succeed in court or in
Congress.

 
 
 

Effect of HSA on Standard Pro38's

Post by RayDunak » Thu, 17 Apr 2003 10:43:15


<< Thanks for pointing this out to me. I didn't relize they had APCP in them
because most of their pages list it as a Thermoplastic Propellant which I
thought was different .>>

APCP stands for "Ammonium Perchlorate Composite Propellent". Any propellent
using AP as the oxidizer
with a binder would be considered APCP, regardless of the type of binder.
"Regular" APCP uses a type of synthetic *** that starts out as a liquid
resin. Thermoplastic starts out as a powdered solid, and after being mixed with
the AP and other ingredients, must be heated to make it melt into a single
grain.

 
 
 

Effect of HSA on Standard Pro38's

Post by Mark Knap » Thu, 17 Apr 2003 22:48:55


Thank you David for the information. This is the kind of information we need
from users not the usual non-sense that users post. So if I understand you
right since the Pro38 have a 1.4c classification for what ever reason then
they are possibly exempt from the HSA.  Thanks

Mark Knapp


Quote:
> As far as I can tell, the exemption status of the Pro38's is fuzzy.

> The original ATF exemption was for motors classified by the DOT as Class
> C "Toy Propellant Devices". This exemption became problematic in the
> early 90's when the DOT revamped their regulations to bring them into
> line with the United Nations hazardous materials designations. As part
> of that, the toy propellant device definition vanished. The ATF
> exemption vanished completely (by mistake?) in 1998. The ATF has been
> saying since 1994 or so that only motors with less than 62.5 gram
> assembled weight are exempt. This is a lie because that rule has never
> (until now) been through the required regulatory process. Right now
> there are only two defensible positions: 1) No rocket motors are exempt.
> Even Estes. 2) Class C toy propellant devices are exempt.

> Aerotech has documents from the DOT showing designations for their "Easy
> Access" reloads as Class C "toy propellant devices" so they are exempt.
> Aerotech has to jump through "inner packaging" hoops to get them a 1.4C
> classification.

> Pro38's do not have a designation as a toy propellant device by the DOT.
> Pro38's are shipped as a fully assembled (almost) motor. Just slide into
> a motor tube. How they got a 1.4C classification for this I do not know.

> You could make a case that Pro38's are regulated now.

> Oddly, Pro54's are classified as 1.4C as well but at least one vendor
> requires a LEUP for purchase.


> > Hi,
> >     Thanks for pointing this out to me. I didn't relize they had APCP in
> > them because most of their pages list it as a Thermoplastic Propellant
which
> > I thought was different . What about the 62.5 gram's listed for the
Classic
> > Pro38 wouldn't this then make them exempt from HSA or as far as the
Pro38
> > goes what does this really mean when they use it .  Thanks

> > Mark Knapp



> >>From the MSDS on the Pro38 site:

> >>"These articles contain propellant and delay charge modules which
> >>consist primarily of ammonium perchlorate (NH4ClO4) dispersed in
> >>synthetic ***."

> >>Sounds like APCP to me.

> >>Classified as UN0351, Articles, Explosives, N.O.S.


> >>>Hi,
> >>>     I was wondering if anybody could shed some intelligent light on
the
> >>>standard Pro38's and if they will also be exempted since they are not

> > APCP

> >>>and listed as 62.5 grams. Again no philosophy just respond with real

> > answers

> >>>as best as we know them.  Thanks

> >>>Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by David Schult » Thu, 17 Apr 2003 11:48:08


Oh the shame! I have been accused of increasing the signal to noise
ratio of RMR. :-)

In an attempt to return the S/N to normal, I provide the following link:
http://zapatopi.net/afdb.html

If your Pro38 dealer is currently requiring you to fill out an ATF form
5400.X or present a permit when you purchase them, then you will need a
permit in May. If not, then you should be able to continue purchasing
them as before.

Quote:

> Thank you David for the information. This is the kind of information we need
> from users not the usual non-sense that users post. So if I understand you
> right since the Pro38 have a 1.4c classification for what ever reason then
> they are possibly exempt from the HSA.  Thanks

> Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by Jerry Irvin » Thu, 17 Apr 2003 12:09:47




Quote:
> Oh the shame! I have been accused of increasing the signal to noise
> ratio of RMR. :-)

> In an attempt to return the S/N to normal, I provide the following link:
> http://zapatopi.net/afdb.html

> If your Pro38 dealer is currently requiring you to fill out an ATF form
> 5400.X or present a permit when you purchase them, then you will need a
> permit in May. If not, then you should be able to continue purchasing
> them as before.

Now June or later.  Buy in bulk now.

All brands.

Yes all :)

Quote:


> > Thank you David for the information. This is the kind of information we need
> > from users not the usual non-sense that users post. So if I understand you
> > right since the Pro38 have a 1.4c classification for what ever reason then
> > they are possibly exempt from the HSA.  Thanks

> > Mark Knapp

--
Jerry Irvine, Box 1242, Claremont, California 91711 USA

Please bring common sense back to rocketry administration.
Produce then publish.  http://www.usrockets.com
 
 
 

Effect of HSA on Standard Pro38's

Post by Greg Cisk » Thu, 17 Apr 2003 15:19:44



Quote:
> Thank you David for the information. This is the kind of information we
need
> from users not the usual non-sense that users post. So if I understand you

You mean the guy in his undies response?

:-)

--


Quote:
> right since the Pro38 have a 1.4c classification for what ever reason then
> they are possibly exempt from the HSA.  Thanks

> Mark Knapp



> > As far as I can tell, the exemption status of the Pro38's is fuzzy.

> > The original ATF exemption was for motors classified by the DOT as Class
> > C "Toy Propellant Devices". This exemption became problematic in the
> > early 90's when the DOT revamped their regulations to bring them into
> > line with the United Nations hazardous materials designations. As part
> > of that, the toy propellant device definition vanished. The ATF
> > exemption vanished completely (by mistake?) in 1998. The ATF has been
> > saying since 1994 or so that only motors with less than 62.5 gram
> > assembled weight are exempt. This is a lie because that rule has never
> > (until now) been through the required regulatory process. Right now
> > there are only two defensible positions: 1) No rocket motors are exempt.
> > Even Estes. 2) Class C toy propellant devices are exempt.

> > Aerotech has documents from the DOT showing designations for their "Easy
> > Access" reloads as Class C "toy propellant devices" so they are exempt.
> > Aerotech has to jump through "inner packaging" hoops to get them a 1.4C
> > classification.

> > Pro38's do not have a designation as a toy propellant device by the DOT.
> > Pro38's are shipped as a fully assembled (almost) motor. Just slide into
> > a motor tube. How they got a 1.4C classification for this I do not know.

> > You could make a case that Pro38's are regulated now.

> > Oddly, Pro54's are classified as 1.4C as well but at least one vendor
> > requires a LEUP for purchase.


> > > Hi,
> > >     Thanks for pointing this out to me. I didn't relize they had APCP
in

> > > them because most of their pages list it as a Thermoplastic Propellant
> which
> > > I thought was different . What about the 62.5 gram's listed for the
> Classic
> > > Pro38 wouldn't this then make them exempt from HSA or as far as the
> Pro38
> > > goes what does this really mean when they use it .  Thanks

> > > Mark Knapp



> > >>From the MSDS on the Pro38 site:

> > >>"These articles contain propellant and delay charge modules which
> > >>consist primarily of ammonium perchlorate (NH4ClO4) dispersed in
> > >>synthetic ***."

> > >>Sounds like APCP to me.

> > >>Classified as UN0351, Articles, Explosives, N.O.S.


> > >>>Hi,
> > >>>     I was wondering if anybody could shed some intelligent light on
> the
> > >>>standard Pro38's and if they will also be exempted since they are not

> > > APCP

> > >>>and listed as 62.5 grams. Again no philosophy just respond with real

> > > answers

> > >>>as best as we know them.  Thanks

> > >>>Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by Doc » Thu, 17 Apr 2003 18:48:05



Snip

Quote:

> Oddly, Pro54's are classified as 1.4C as well but at least one vendor
> requires a LEUP for purchase.

As far as I know, ALL Pro 54 vendors require an LEUP.

--
Drake" Doc" Damerau 79986 L2
President NEPRA, NAR Section 614
www.nepra.com
HPR Strength of Materials Site:
http://rocketmaterials.org
(Remove "my shorts" to email me)

 
 
 

Effect of HSA on Standard Pro38's

Post by Robert DeHat » Thu, 17 Apr 2003 20:35:24


Quote:

> Pro38's do not have a designation as a toy propellant device by the DOT.
> Pro38's are shipped as a fully assembled (almost) motor. Just slide into
> a motor tube. How they got a 1.4C classification for this I do not know.

They paid to have the testing done to have them classified this way.

Quote:

> You could make a case that Pro38's are regulated now.

> Oddly, Pro54's are classified as 1.4C as well but at least one vendor
> requires a LEUP for purchase.


> > Hi,
> >     Thanks for pointing this out to me. I didn't relize they had APCP in
> > them because most of their pages list it as a Thermoplastic Propellant
which
> > I thought was different . What about the 62.5 gram's listed for the
Classic
> > Pro38 wouldn't this then make them exempt from HSA or as far as the
Pro38
> > goes what does this really mean when they use it .  Thanks

> > Mark Knapp



> >>From the MSDS on the Pro38 site:

> >>"These articles contain propellant and delay charge modules which
> >>consist primarily of ammonium perchlorate (NH4ClO4) dispersed in
> >>synthetic ***."

> >>Sounds like APCP to me.

> >>Classified as UN0351, Articles, Explosives, N.O.S.


> >>>Hi,
> >>>     I was wondering if anybody could shed some intelligent light on
the
> >>>standard Pro38's and if they will also be exempted since they are not

> > APCP

> >>>and listed as 62.5 grams. Again no philosophy just respond with real

> > answers

> >>>as best as we know them.  Thanks

> >>>Mark Knapp

 
 
 

Effect of HSA on Standard Pro38's

Post by Kurt Kesle » Thu, 17 Apr 2003 21:37:32




Quote:
> Thank you David for the information. This is the kind of information we need
> from users not the usual non-sense that users post.

Yes, let's make some rigid rules and allow no OT posts.  Only questions
and their corresponding (on topic) responses are to be allowed.  Then we
can enjoy all 12 posts RMR would get per day.

Or maybe you are referring to "Jerry answers" when you speak of
nonsense.  Only your killfile can help with that problem.

I figure 75% of us are guilty of the OT violation.  Killfiling us should
get you down to the 12 posts per day.

--
Kurt (full o' nonsense) Kesler