Steve_Shannon

I wish David success and fortitude as he begins to explore this uncharted territory of "a process for which there is no process". By doing this he benefits all of us. If he succeeds, that is one less reason to have a LEUP. We should support that effort by finding something to order from him.

I have dealt with David, but he was absolutely excellent to work with. As sometimes happens with anybody he misunderstood what I had ordered (or I ordered incorrectly) and he made good at his own expense. I feel that I learned more about his character from that than if the order had been handled perfectly at first.

ncrocketeer

If it's LEUP free, I will fund ANY business who furthers that progress with many orders, and I do mean many. Positive things are happening in this hobby, and I have watched these things closely. The hobby benefits from these folks who do this work. I applaud them, and will support them.

I will be one of the first in line to order 100 Igniters of various sizes when that happens.

Congratulations David!

rcktnut

I'll be the second in line. I haven't used anything other than the Cosmos E- Matches for my deployment charges. Never had a failure!! My supply is dwindling. I'm getting nervous, I only have enough for 8 more DD flights.

sandmantoy

Congrats! David, I wish you all the best on this venture and applaud your efforts

DarkChevelle

Congrats David. Your persistence in this hobby is showing more and more.

Just Jerry

I couldn't agree more. So is the inverse true? You will avoid like the plague firms who unnecessarily require LEUP when it is not needed, or cause LEUP to be required despite regulations clearly stating otherwise?

I only ask because we already experienced this in a proveable way, and the list of firms who did that are well known, and should be shunned hard.

IMHO.

Just Jerry

Steve_Shannon

I will not avoid dealing with a firm that required a LEUP because they were unsure of how the ATF might treat them or because it would be too costly to become a party in a "landmark case". I simply don't have the knowledge necessary to condemn others. If a vendor has done something that can be shown to me to be detrimental to the hobby out of purely selfish motives, then I would not patronize them, but the proof would have to be indisputable.

dwmzmm

I received my mail order from Quest on December 26, 2007; in it was the Flat Cat B/G kit and two packs of the Q2 igniters. It was delivered to my front door via USPS 1 1/2 weeks after sending my payment (money order) with the order form to Quest's address in Colorado. All I had to pay was the standard shipping and handling; no hazmat fees.....

David, what's the story of the Hot Shot's? I still have plenty of uses for them.

QuickBurst

David and all

From what I understand any "Igniter" that is individually packaged and sold as an "igniter" requires a LEUP. Many other companies are doing as I did; selling igniters stand alone. According to what I am told this is illegal.

Estes individually packages and sells "igniters". However the ATF states that these are not igniters. They will not tell me what they are but stand firm on the fact that they are not igniters. The package describes them as igniters, the instructions on the motors state that they are igniters and the catalogue states that they are igniters.

My question to the ATF is "If they are not igniters than what are they?" After spending many hours trying to get an answer they have now assigned my case to an individual that will come up with an answer. This person is Mr William O'Brian, who was assigned by Gary Bangs. Gary Bangs is the director of Public Safety ETB (Explosives Testing Branch). When I called Mr Bangs I went straight to the point. I stated that I want the same exemption that other companies have. It was then that I was told that there is no exemption and there is not an existing process to obtain one.

The ATF has stated that I should be treated fairly and have the same rights as other companies that are doing the same thing. This is when Mr O'Brian entered the story. It is his responsibility to see to it that I am treated fairly. I am still in contact with Mr O'Brian, but there is not a definite decision.

I expect I will receive some sort of exemption. My gut feeling is that some of my products will be exempt at one point in time or another. However I don't know which will be what and I don't know when.

In the meantime, all of my igniters require a LEUP. Including the Hot Shot.

The documentation from the testing facility is in the ATF's hands, I'm waiting for direction now. How long? I have no idea, I do know that these things take a great deal of time and effort. For example, DOT told me approval would take between six and eight weeks. In reality it took eighteen. the only reason I got approval within 18 weeks was because I was calling them three times a week.

David Bachelder
DBA~QuickBurst

UhClem

There is a reason why there is no process for getting an exemption: just look at the law and regulations and you will see.

In the regulations there are two sections that deal with exemptions. The most widely known is at 27 CFR 555.141. This just lists things which are exempt, mostly a restatement of what the law has exempted, but says nothing about issuing new exemptions.

The second is at 555.32 for "special" explosive devices. This section starts out "The Director may exempt certain explosive actuated devices,
explosive actuated tools, or similar devices..." Since an igniter is not a device this section is not applicable to getting an exemption for them. I refer you to the tortured arguments of the ATF in the Propellant Actuated Device NPRM where the ATF goes on at length on the subject of what is and is not a device.

It gets worse when you look at the explosives law. The law at 18 USC Chapter 40 lists several exemptions but does not provide for the ATF issuing any other exemptions on their own. Someone at the ATF apparently noticed this a few years ago and proposed amending the law to provide that authority. That amendment went just as far as the per pound explosives fee/tax in the same proposal: nowhere.

There can be no process since the ATF has no authority to issue the exemption. Although given their past history that might not slow them down too much.

UncleVanya

This is pandora's box. What if the ATF were to decide that the Estes/Quest style igniters were not going to be allowed to remain exempt? The hobby has enough challenge already...

Steve_Shannon

We certainly have had challenges for the last several years, but I recall hearing that Estes type igniters were already commonly found by the ATF in improvised munitions.

It sounds like the ATF is actually trying to be fair about this, although time will tell. I still have a pretty good supply of igniters, but I am going to have to start building my own this year if QuickBurst is not successful.

UncleVanya

I was trying to think of a nice way to say that very thing... thanks for wording it for me. I guess you are right but I trust my government as far as I can throw a large high rise building.

dwmzmm

Thanks, David. Either way, we're hanging in there for you...

QuickBurst

I expect to be treated fairly. I expect to have the same rights as my competition.

I think that if any of you were in my shoes, you would expect the same.

ddmobley

If I recall correctly, the Estes igniter is the choice of IED manufacturers. But like the 62.5 gram APCP exemption, ATF does not have the staff to handle licensing and oversight for the much larger base of model rocketry enthusiasts, but somehow seems to think discriminatory action against the high power crowd is appropriate.

Steve_Shannon

Hell, we're counting on it!

UncleVanya

Sorry - my wording may have mislead folks. I am happy that you are trying to resolve this and get equal treatment - but suspicious that our government will do the right thing and allow you to ship these without requiring a LEUP.

It was my understanding that E-matches if properly tested and not classified as igniters would not require HASMAT fees but that some vendors had decided it was easier to test them and certify them for DOT purposes as igniters. How does this match your experiences dealing with DOT - is this just a myth or is it true?

QuickBurst

I'm hoping the government allows me to sell to folks that do not possess a Federal Permit.

This opens a small market considerably. Being limited to permit holders cuts a small market to a very small market.


"It was my understanding that E-matches if properly tested and not classified as igniters would not require HASMAT fees but that some vendors had decided it was easier to test them and certify them for DOT purposes as igniters. How does this match your experiences dealing with DOT - is this just a myth or is it true?"

All explosives have to be tested by an independent lab. These results are sent to DOT for approval. If the lab test results come back UN0454 (or something similar) a 1.4S (Igniters) explosive then you can ship less Hazmat only if you ship USPS Ground.

In order to ship USPS Ground you must have a signed letter of approval from the Office Of Mailing Standards. This permission letter is not hard to get. It consists of a few form and copies of your test documentation.

The problem with USPS Ground is the weight limit.

From my limited memory:
USPS Ground is limited to 30 grams of explosive. My number may be a little off but I'm in the ball park. I'm sure someone with a more accurate number will chime in. There is also a per package weight limit, however I can't remember what it is. Go to the USPS website and look up the Domestic Mail Manual (DMM). Search the DMM for "rocket motors" it explains things clearly.

Haz Mat Ground shipping enjoys higher weight limits, 25 lbs of explosive can be in any one box. The downside is HazMat fees. The fees are not collected by DOT. The carrier (FedEx, UPS, or any other hazardous freight carrier) keeps the money.

The simple answer is yes. Limited quantities of properly classified explosives do not always require HazMat fees.

Look up CFR49. If that dull read doesn't kill you, then try The Orange Book (ATF), if there is a ounce of energy left in your body move on to The Domestic Mail Manual.

All of the answers are found there.

UncleVanya

I had trouble finding this. The online version of DMM did not mention rockets. However eventually I found this:

http://pe.usps.gov/text/pub52/pub52c_002.html

In this doc it clearly states that 25lbs is the per package limit for Toy Propellant devices (which each are limited to 30g and < 80Ns) I did not see anything that clarifies why Aerotech can ship motors with two 30g grains - but I assume this is codified elsewhere or is a standing exception.

Steve_Shannon

Aerotech "packages" its grains individually (by placing them in those heat sealed plastic bags which then go within the larger static resistant bag that contains the entire reload). Are they claiming that each propellant grain is one device? The letter from USPS to AT clearly states no more than 30 g per device. Here is the USPS letter to AT.

QuickBurst

Seems like I forgot that the package limit is 25 lbs. Much more than I remembered.

Funny thing, HazMat Shipping with FedEx has a weight limit of 25 lbs of explosive, for igniters, this means the lead wire does not count (only the weight of explosive) so the package could weigh more than 25lbs.

USPS has limited the entire package to 25 lbs.

xman

OK. So assuming a person has a LEUP and wants to purchase 10 slim gems for example, will he have to pay HAZMAT in addition to standard shipping costs?

Ken.

Steve_Shannon

No, if you have it sent via mail (assuming David is set up to do that). Yes, if you have it shipped via FedEx.

dwmzmm

When I placed my order to Quest in mid-December for the two packs of the Q2 igniters, it was stated in their shipping information that if the customer chooses to have his/her order delivered via USPS, there's no hazmat fees required. That's how I received my order (without any hassles, I might add).

WillCarney

Congrat's Dave. And thanks for sticking in there. A lot of small companies would have just quit. Your products are great and I will be ordering some igniters as soon as the details are worked out for shipping. It's nice to have a vendor stay with it, especially when they have great products.

LEUP or not I will always order stuff from Quickburst.

William

QuickBurst

Currently, yes.

In the near future, probably not.

QuickBurst

Currently, yes.

In the near future, probably not. I am still in the process of getting USPS approval.

Just Jerry

I usually do not miss any opportunities to criticize Errortech, but in DOT parlance there are substances and articles. A reloadable motor or kit motor grain is an article. It is the shipped form of the active ingredient that is regulated. If you have any power of reloadable motor or kit motor that consists of several of these articles, the end user combines into a field assembeld unit, it is compliant.

Remember we are talking about DOT and USPS and not about ATF, who after illegally declaring propellant an explosive, also said it is the intended end use that governs, not the packaging of the unit. They further let explosives handlers have unpermitted folks handle explosives on the site, but not rocketeers. ATF hates rocketry and rocketeers.

DOT and USPS regulate single use motors as the assembled unit. This without consideration for the number of individual grains, or the fact propellant is not an explosive, or the fact APCP propellant itself burns at a rate that drops it below even the flammable solid threshold, much less the DOT explosives threshold, thus illegally regulating the substance.

For decades the rocket industry has let this stand and the ONLY company I am aware of that ever had propellant classified by actual testing, not analogy, was ACS-Reaction Labs, and that test declared propellant cylinders under 3.3 x 36" to not be an explosive. That test was conducted by the director himself of the Bureau of Explosives.

Efforts to include that in the ATF lawsuit were rebuffed.

Aerotech (and Magnum and TRA) led the way to requiring ATF permits for many years before the ATF itself did. They called that practice "over-compliance". I call it baiting a monster to regulate you. It worked.

Just Jerry