An overview of how to do it by someone who has three times!

I HAVE READ WITH GREAT INTEREST the recent article by Tim Van Milligan and the resulting desire to form a new rocket motor manufacturing consortium. There are lots of great points and opinions regarding this subject posted here. Many of these postings indicate that most folks don't really understand what is involved to manufacture model rocket motors legally and safely.

The longevity and success of our hobby is directly attributable to my father's concept of commercially manufacturing the motors to keep the consumer from trying it. Vern Estes efforts to perfect the manufacturing process and develop consistent high quality motors were the catalyst that made this hobby grow and prosper. Making model rocket motors is considerably more than just pressing black powder into cardboard tubes.

Here is a brief outline of what it takes to bring a model rocket motor manufacturing facility online. I've done it three separate times across the country over the past ten years.

Failure to comply in any one of the areas can lead to accident, injury, death, or prison time. (Yes, certain OSHA violations are criminal and you can go to jail).

The following is an extensive but not totally inclusive outline of what it takes.

Capital
Just to get a compliant and safe facility to operate one machine will take $450,000 exclusive of land and working capital costs.

Equipment
The going rate these days to fabricate a well designed easy to operate and maintain machine is about $150,000 a copy. Figure another $75,000 for the additional equipment required to process and handle materials.

Facility
The process buildings, storage magazines for the facility will run another $75,000+. On-site improvements will vary by site and add up quick. Examples are good usable roads (you have to move materials in and out of the facility and most of the time it is by big trucks) and electric power (3 -phase is a must to run efficiently) At the facility outside of Yuma we had to bring in three-phase power from a mile away and it cost $40,000!

Working capital
This is the big one that nobody ever thinks about. It takes lots of money to purchase materials and pay for labor. Black Powder is expensive and is also very expensive to ship. So you have to buy several thousand pounds at a time. Depending on how you formulate your delay mix, you may need to purchase large quantities of other chemicals also. As in all manufacturing there is efficiency of scale in purchasing raw materials.

Regulatory compliance
Unfortunately, Federal, State, and local regulatory issues are growing more complex every minute. Let me say that there is no way to cut corners with these issues. Here's the current list of what you'll need to comply with.

Zoning
You'll need a correctly zoned piece of land. Most communities don't like pyrotechnic or explosive manufacturing and will make you locate way out in "no man's land".

Site use
Most municipalities require any potential land use to be approved regardless of the zoning. An A-1 industrial zoning may specifically allow explosive manufacturing but the town council may say no to your request to use the land this way. This process can be unbelievably long and can result in months of work ending in one quick council vote.

Building permit
If you're lucky enough to get your facility approved you'll need a building permit before you can start construction.

BATF license
You'll need to get a low explosives manufacturing license and get your magazine locations approved by the Bureau of Alcohol Tobacco and Firearms.

EPA - SARA notifications
The Emergency Planning and Right to Know Act require various types of hazardous manufacturing operations to notify the local Emergency Planning Committee of the location and quantity of various listed materials. Also, any waste generated by your operation must be disposed of by safe legal means. The going rate to incinerate Flammable Solids NOS reject motors is $5.00 a pound plus proper shipping containers (metal $15.00 a pop - non reusable)(that $5.00 /pound includes a minimum of 15% water to make the materials inert during shipping)

OSHA 29CFR Sec 1910
This is very extensive and onerous. Basically you must develop a written Standard Operating Procedure (SOP) for every operation that takes place. You must document the "process safety analysis" that is done that assures maximum employee safety. You must perform regular documented training of all your employees.

NFPA 1125 compliance
This code is considered the "Bible" of how to design and operate a Model Rocket Motor Manufacturing Facility. Local Fire Authority having Jurisdiction inspection and approval of your facility. Passing this is your ticket to operating the facility. They will inspect EVERYTHING and all of your processing to be sure you are in compliance with BATF, NFPA and any local fire regulations.

Workman's Comp insurance
It is illegal to operate a manufacturing business without having Workman's Comp Insurance. The rates are based on the hazard level of the work being performed. Explosives' manufacturing is very hazardous work!

General liability and fire insurance
Not required but it is a very wise thing to have your facility insured in case of loss.

Experience
Ever hear the joke about the repairman who is called to fix a machine? He shows up takes one look at the machine and hits it with a wrench and it starts working again. He submits a bill for $100 broken down as: Hitting machine $5.00, knowing where to hit the machine $95.00!

There is a definite science to making black powder rocket motors but there is also an "art" that is not definable. This manufacturing process is tough and there is no textbook to follow. It is very sensitive to environmental issues like temperature and humidity and requires very close tolerances on materials. Sometimes you have to throw away 15-20% of your tubes because they are too big or too small. (The design of the Micro Maxx plastic casing really helped with this problem). The wrong mesh size on your delay mix can cause delay times to run all over the place. The machines themselves can be mystical in their performance. My first machine was a re-built MPC pneumatic indexing machine that we quickly nicknamed "Christine" after the Steven King novel. She would do things that could not be explained or duplicated!

Run up time
It will take you six months to break in your facility and hire/train your operators before you'll produce a quality, saleable rocket motor. Oh, and remember that you had to locate your facility out in "no man's land"? Well, try getting good quality employees that are willing to make the drive every day! During this six months you'll generate an awful lot of reject rocket motors that must be destroyed (remember it costs $5.00/pound). You'll need a good AQL plan and ongoing maintenance for the entire facility. You'll break drifts, bend rams, clog journals, and curse yourself for ever getting into this!

So now you're making rocket motors! But wait you can't sell or ship them yet. You've got more hoops to jump through!

Explosives bureau
You must submit your rocket motors to Dr. Chang to have him issue a DOT classification letter.

EX number
Now you must submit the classification letter from the Explosives Bureau to the DOT to get an EX number assigned.

NAR certification
You must submit you motors to the NAR for testing and certification.

California State Fire Marshal
To sell your motors in California you must get a license and approval from the California State Fire Marshal.

UN Box testing
The boxes you ship your product in must be tested and certified to meet the UN Specifications for shipping Hazardous Materials.

Wasn't this fun! Estes, Quest and Aerotech do everything I just described to bring you quality motors at an affordable price. You must manufacture and sell about 1.5 million black powder motors ("A" through "C") a year to break even on a manufacturing operation. This is why it is very hard to attract serious venture capital to this industry. There is a low potential for "return of" let alone "return on" your investment with a burgeoning legal and regulatory environment. There are plenty of better places to put your money to work as an investment. It is highly unlikely that we will ever see another major company enter this market to manufacture model rocket motors.

If after reading this you still want to manufacture model rocket motors, you must suffer from that famous disease "Model Rocket Nut" more than I do!