[LUNAR Announce:] Shipping of Model Rocket Engines/Motors and Igniters

Thu Sep 29 21:07:44 UTC 2011

Many of you who are NAR members have received the following e-mail. I'm
passing this on for those of you who don't belong to the NAR, but we need
your help in preserving the status quo.

It seems there's an administrator at the DOT (Department of Transportation)
who has political ambitions, and the cause he's decided on is stopping the
"hazardous" shipping of model rocket motors without an explosives permit.
We're talking everything down to MicroMaxx here. These motors are currently
shipping under a rule called DOT - SP 7887, which governs the shipment of
"flammable solids." The current rule has been in place for 33 years and
there have been no shipping incidents with the hundreds of millions of
motors shipped during that time. That's an astounding safety record, which
is what brings the administrator's motives into question. Moving the motors
from "flammable solids" to "explosives" would essentially kill all LP
rocketry since the shipping permit would cost more than the motors.

The message below is the original e-mail from Mary Roberts, the person who
really runs Estes (don't let anyone tell you different!) explaining what
they're trying to accomplish. There should also be four files attached to
this message. Three of them are background documents, just FYI. The two
PDF's are the original proposal from the DOT. The "Hobbico-Estes" file is
the letter from the Hobbico lawyer with the company's response. Finally, the
"Sample Letter" is where you come in. It is the letter that they would like
you to send to the DOT requesting that DOT - SP 7887 remain in effect. You
can send it by e-mail or paper mail (preferably on a letterhead). E-mail is
find, but paper mail still carries more weight in DC. I'm going to be
sending mine on ARA Press letterhead, but whatever you do, Mary asks that
you copy her on your submission (the address is in the sample letter and
she's cc'd on this message.

Please help the hobby avoid another costly legal battle with the feds!

- Jack

Jack Hagerty, LUNAR #0002

http://www.lunar.org

"If God had meant us to be a spacefaring race,
He would have given us a moon" -- Krafft Ehricke

From: Mary Roberts [mailto:MRoberts at centurims.com] 
Sent: Thursday, September 22, 2011 5:12 PM
To: Tommy Billings; Tim Ziegenbein; Tim VanMilligan; Robert Edmonds; Robert
DeHate; Peter Lawall; Michael Sunseri; Michael Stoop; Ken Brown; John Dyer;
Jim Flis; Fred Ziegler; David Bachelder; Carl McLawhorn; Bob Korman; Bill
Saindon; Barry Lynch; Anthony Cesaroni; Angelo Castellano; Andy Jackson;
Adrian Adamson; Art Applewhite; Jack Hagerty
Cc: Vince Huegele; Ted Cochran; Stewart McNabb (work); Joyce Guzik; John
Lyngdal; Hochheimer, John; Jennifer Ash-Poole; Tom Ha; Gary C. Rosenfield;
Bill Stine
Subject: Shipping of Model Rocket Engines/Motors and Igniters

          URGENT NOTICE- YOUR SUPPORT IS NEEDED

Re:  DOT-SP 7887, DOT-SP 7887 Show Cause Letter and Estes' Response 

Attn: Model Rocketry Product Manufacturers:

As a participant and supplier in the world of model rocketry, we believe you
have a stake in the shipping of model rocket engines and igniters.   We are
writing to advise you of recent developments and to ask for your action and
support.  

On August 15, 2011 all grantees authorized to use DOT - SP 7887 received a
Show Cause letter from the US Dept of Transportation (DOT).    The Special
Permit, DOT - SP 7887 allows the shipment of model rocket motors (engines)
and igniters in limited quantities to be shipped as Flammable Solids.  The
Show Cause letter advised that additional testing of model rocket motors is
needed to determine if they may be excluded from the classification of
Explosives.  After an evaluation of the testing to which the letter
referred, it was determined that model rocket motors would not meet the
criteria for exclusion.

The letter further advises that whether or not model rocket motors meet the
criteria, DOT is proposing to terminate the Special Permit. The Special
Permit has been in place since 1978.  In 33 years there have been no
incidents involved in the shipping and transporting of model rocket motors
and igniters.  

Model rockets, engines/motors and their igniters are shipped to educators,
youth group leaders, children and their families for educational and
recreational purposes.  Model rocket motors and igniters have an excellent
record with regard to shipping and transportation.   We are very concerned
that having to use an Explosives label on packages of engines and igniters
projects a frightening message and an exaggerated risk to those receiving
the packages.  Model rocket engines and igniters do not ignite spontaneously
and they don't EXPLODE.  They are propellant devices.    

Shipping engines and igniters as 1.4S explosives is not a great deal more
difficult from a technical standpoint nor is it a lot more expensive.
However, the word "explosives" on a bright orange hazardous materials label
creates more concern than does a flammable solid label!  Boxes of model
rocket engines and igniters sitting in the back rooms of hobby shops, large
distribution centers, wholesalers' warehouses and school supply closets will
likely garner far more attention from fire prevention personnel, insurance
investigators, school administrators, OSHA inspectors and most importantly
from the parents of young rocket enthusiasts!  

Therefore, Estes as well as Quest Aerospace and RCS/Aerotech have sent
responses to the US DOT requesting that the Special Permit, DOT - SP 7887
not be terminated.   And we are asking re-shippers of our products to send
responses to DOT as well as this will impact their shipments. 

As a supplier of model rocket products, you too have an interest in the
future of DOT-SP 7887.  Termination of the Special Permit may have a very
negative and long-term impact on our hobby.  

If you believe as we do, that termination of the Special Permit is not
warranted, we ask you to send an email or letter via email supporting our
requests to keep the Special Permit in place and to protest its termination.
The email or letter or both should be sent to DOT as soon as possible and
preferably prior to October 2, 2011.  To assist you, a sample letter is
enclosed that you may customize.  

The email address to which emails and letters should be sent is:
specialpermits at dot.gov   Please use "DOT-SP 7887 Show Cause Response" as the
email subject.  To assist us, please bcc mroberts at centurims.com or one of
the other engine manufacturers.  

As you will note in Estes' response to the Show Cause letter, we intend to
petition for permanent relief.  If we are to succeed we will need the
support of the industry and consumers alike.

Therefore we again ask for your support and action on this important issue.
Thank you.  We will keep you up-dated!

Sincerely,

Mary Roberts

Mary Roberts 

Technical Services

Copies of the Special Permit, Show Cause Letter, Estes' Response and Sample
Letter are attached.  

____________________________________________________________
60-Year-Old Mom Looks 27
Mom Reveals Free Wrinkle Trick That Has Angered Doctors!
http://thirdpartyoffers.juno.com/TGL3141/4e84de362b7f68ba418st05duc
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lunar.org/pipermail/announce/attachments/20110929/6a862bee/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: DOT-SP7887-2014Reduced.pdf
Type: application/octet-stream
Size: 768667 bytes
Desc: not available
URL: <http://lunar.org/pipermail/announce/attachments/20110929/6a862bee/attachment.obj>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: DOT-SP7887 Show Cause Letter.pdf
Type: application/octet-stream
Size: 54015 bytes
Desc: not available
URL: <http://lunar.org/pipermail/announce/attachments/20110929/6a862bee/attachment-0001.obj>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: Hobbico-Estes response to show cause letter.docx
Type: application/octet-stream
Size: 82307 bytes
Desc: not available
URL: <http://lunar.org/pipermail/announce/attachments/20110929/6a862bee/attachment-0002.obj>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: SP7887 Sample Letter.doc
Type: application/msword
Size: 26624 bytes
Desc: not available
URL: <http://lunar.org/pipermail/announce/attachments/20110929/6a862bee/attachment.doc>