From: jws31@thor.albany.edu (John W Sicker)
Subject: Summary of NFPA meeting
Originator: jws31@thor.albany.edu
Organization: State University of New York at Albany
Distribution: usa
Date: Sun, 12 Apr 92 21:01:56 GMT

This is a cross post from compuserve on the modelnet forum section 8.
I thought that this news group would be very interested in this.





________________________________________________________________________________
                  BRIEF REPORT ON NFPA COMMITTEE MEETING
                     National Association of Rocketry

The following is a summary of the meeting of the NFPA Committee on
Pyrotechnics held in Phoenix, AZ on 6-8 April 1992.  This summary has been
reviewed by J. Patrick Miller, President of the National Association of
Rocketry; G. Harry Stine, Chairman of the NFPA Committee on Pyrotechnics;
and Vernon D. Estes, member of the NAR Board of Trustees.  All three
attended and participated in the Phoenix, AZ meeting.


A. COMMITTEE AND CAUCUS ACTIONS: 

     1.   A third attempt to process an temporary interim amendment (TIA)
          to NFPA 1122-1987 "Code for Unmanned Rockets" was withdrawn by
          the rocketry caucus. (The rocketry caucus is an unofficial group
          of NFPA Committee members and interested parties who caucus on
          NFPA rocketry issues to present a unified consensus to the NFPA
          Committee and government agencies. Its members include people
          from NAR, Tripoli, and the model rocket manufacturers. This TIA
          would have added provisions concerning reloadable model rocket
          motors to NFPA 1122-1987.  The TIA would have become part of the
          current NFPA 1122 within 3 months if it had passed a mail ballot
          of the Committee members, elicited no adverse public comments
          when published by the NFPA, and was acceptable to the NFPA
          Standards Council. The rocketry caucus believed that the TIA
          stood virtually no chance of making it through this process a
          third time. 
 
     2.   The complete rewrite of NFPA 1122 was withdrawn. The reloadable
          TIA elements will be incorporated into a revision of NFPA
          1122-1987 which will enter the NFPA approval cycle and hopefully
          be published as NFPA 1122-1994. This was determined by the
          rocketry caucus and the Pyrotechnics Committee members to be the
          fastest and most positive way to revise NFPA 1122-1987 which is
          now two years past its normal revision cycle. 
 
     3.   NFPA 1127 Code for High Power Rocketry was presented to the NFPA
          Committee by Charles Rogers, President of Tripoli Rocket Society.
          The Committee voted to table further discussion of NFPA 1127
          until the Pyrotechnics Committee meeting on Long Island on 5-7
          October 1992. This will allow time for CPSC to make its
          determination on reloadable motors and time to obtain letters of
          regulatory clarification from several government agencies. 
 
     4.   A tentative interim amendment was written that would change NFPA
          1122-1987 Paragraph 3-1.5 to bring the maximum total impulse of
          an individual model rocket motor into concurrence with the
          regulations of the U.S. Consumer Product Safety Commission set
          forth in 16 CFR 1500,85(a)(8)(ii). This would currently limit the
          size of a model rocket motor to 80 newton-seconds.  This TIA was
          voted out for mail ballot and public comment by the Committee. 
  
B. OTHER ROCKETRY MATTERS: 
 
     1.   The video tape of reloadable rocket motor burn tests conducted by
          Scott Dixon of Vulcan Systems, Inc. was shown to the caucus
          members on Sunday, 5 April 1992 and to all Committee members on
          Monday, 6 April 1992. Mr. Dixon was present to respond to
          comments and questions from both groups.  A written report of the
          burn tests was distributed to Committee members and interested
          attendees.
 
     2.   Three video tapes of model rocket burn tests conducted by the NAR
          at two locations were shown to the rocketry caucus on Sunday, 5
          April 1992 and to the members of the Pyrotechnics Committee on
          Monday, 6 April 1992. Mr. Stine was available to respond to
          comments and questions from the viewers but did not comment on
          the videotape of the tests conducted by NAR Standards & Testing
          at MIT on 28 March 1992. A written report of the NAR Burn Tests
          conducted in Phoenix on 20 March 1992 was distributed to
          Committee members and interested attendees. 
  
     3.   The Superstition Spacemodeling Society NAR Section demonstrated
          model and high power rocketry to members of the Pyrotechnics
          Committee on Tuesday, 7 April 1992. While many Committee members
          are still confused about the difference between model and high
          power rocketry, the Committee members were highly appreciative
          that rocketry consumers had invited them to view and participate
          in the activity. Many positive comments were received from
          Committee members, some of whom had never seen model and high
          power rocketry in action before. 
 
C. INTERFACE WITH GOVERNMENT AGENCIES: 
 
     1.   The Pyrotechnics Committee meeting allowed direct interaction
          between rocketry people and individuals from the Consumer
          Products Safety Commission (CPSC) and the Bureau of Alcohol,
          Tobacco, and Firearms (BATF). 
 
     2.   John D. Rogers, CPSC representative on the Committee, pointed out
          that: 
 
          a.   A stay of enforcement was in place that would allow
               Aerotech/ISP to continue to sell reloadable model rocket
               motors while the petition for rule change from Aerotech/ISP
               was in the regulatory rule changing process. Current CPSC
               regulations consider reloadable rocket motors to be banned
               hazardous substances. A change in the wording of the CPSC
               regulations will require between 12 and 24 months to go
               through the regulatory revision process. 
 
          b.   Model rocket motors with 80 newton-seconds or more of total
               impulse are considered to be banned hazardous substances by
               the CPSC because no petition to change the CPSC regulations
               had been made. The regulation exempting a model rocket motor
               from classification as a banned hazardous substance has been
               in place since 1969. This regulation exempts from the
               classification as a banned hazardous substance a model
               rocket motor having a total impulse of less than 80
               newton-seconds. Aerotech/ISP is therefore requesting a stay
               of enforcement that would allow Aerotech/ISP to continue to
               sell Type G model rocket motors. 

               Aerotech/ISP is adding to its petition for rule change a
               request to amend 16 CFR 1500.85(a)(8)(ii) so that a model
               rocket motor with a total impulse of 160 newton-seconds or
               less would be exempt from the classification as a banned
               hazardous substance.  A decision on the stay of enforcement
               is expected to be issued within 4 to 6 weeks. The decision
               on the full rule change will take 12 to 24 months to
               complete.

     3.   The BATF has no problem with model rocketry but is watching the
          area of high power rocketry given the higher total impulses and
          quantities of flammable materials available to consumers in their
          homes. At this time, according to verbal discussion with Daniel
          E. Crowley, BATF representative on the NFPA Pyrotechnics
          Committee, BATF believes there may be no reason to become
          involved in the regulation of high power rocketry.  The NAR will
          request further clarification with the BATF on this important
          point.
 
D. WHAT DOES THIS MEAN TO NAR MEMBERS? 
 
     1.   NFPA 1122 is only a recommended standard produced by a national
          voluntary standards organization. It is not law. It is not a
          regulation. Some jurisdictions adopt NFPA codes into law or
          regulation by legislation that "enables" an authority having
          jurisdiction to do this. An "AHJ" may be a fire official, for
          example. Adoption of an NFPA code into law by the legislative
          process requires time as well as specific action by a legislature
          or town council, for example. NAR Safety Codes are the ruling
          safety and operating standards for NAR members. However, this
          does not relieve NAR members from the responsibility to act in
          accordance with local, state, and federal laws and regulations. 

     2.   CPSC is engaged in an extensive review of their stay of
          enforcement on reloadables.  The Commission expects to have a
          determination in 4 to 6 weeks.  In the meantime, only
          Aerotech/ISP may produce and sell reloadable motors because they
          are the only manufacturer that has obtained a stay of
          enforcement.  Other manufacturers interested in petitioning the
          CPSC for a similar stay of enforcement may do so.  The CPSC
          reviews these petitions on a case-by-case basis.

          At this time the Department of Transportation (DOT) has not
          reviewed the shipping requirements for reloadable propellants. 
          Until this has been done it is not known if the propellants can
          continue to be shipped as flammable solids or if they will be
          required to be shipped and stored as explosives (e.g. Class C or
          Class B).
 
     3.   No prohibition exists for those who wish to fly Type G rocket
          motors provided this is done within local and state laws.        
          G-powered rockets are temporarily considered to be high-power
          rockets and flown under the U.S. High Power Rocket Safety Code. 
 
     4.   FAA waivers must be obtained for operation of rockets of any type
          exceeding one pound in weight or carrying more than 4 ounces of
          slow burning propellant under the FAR Part 101 (49 CFR
          101.1(a)(3)(ii)). 
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