WORLD WIDE WEB — Years of hard work paid off recently for Charles Simpson of the United Kingdom Rocketry Association, where he functions as a liaison with the UK's Health and Safety Executive (HSE), securing certificates of regulatory exemption for the majority of fliers there.

Simpson served for years as the UKRA chairman, and in this capacity he began lobbying HSE for purchase and storage exemptions for small quantities of rocket motors and other materials classified in the United States as "explosives."  After stepping down as chairman, Simpson stayed on as HSE Liaison, working diligently to remove or eliminate burdensome regulatory hurdles for the country's hobby rocketry enthusiasts.

That five year effort paid off on December 4th, 2007, when HSE signed off on the Certificates of Exemption for Manufacture and Storage of Explosives Regulations (MSER) and Control of Explosives Regulations (COER) that granted to following:

MSER Exemption

The main effect of the MSER exemption is that:

• individuals may keep up to 5 kg (net mass) of articles with UN numbers 0186, 0272, 0349, 0351 and 0471 without the need for a registration or storage licence provided that:
  (a) each individual article contains no more than 1 kg (net mass) of explosive
  (b) the articles are intended for use in the propulsion of rocket motors
  (c) they are kept in a safe and suitable place.
• individuals keeping no more than 5 kg of these articles are exempted from separation distance requirements if they are also keeping small quantities of shooters powder (i.e. black powder or smokeless powder).

COER Exemption

The COER exemption certificate means that:

• articles with UN numbers 0186, 0272, 0349, 0351 and 0471 may be acquired and kept without the need for an explosives certificate from the police provided that:
  (a) each individual article contains no more that 1 kg (net mass) of explosive
  (b) the article is intended to be used in the propulsion of model rockets
  (c) they are kept in a safe and suitable place
• individuals (i.e. suppliers) are exempted from the requirement not to transfer the articles covered by the exemption certificate unless the recipient has an explosives certificate;
• the restrictions in COER relating to "prohibited persons" do not apply
• record keeping and loss reporting requirements in COER do not apply.

The effect of the exemptions grants users to purchase and store motors of up to 1 kg, or 2.2 US pounds, which extends into the J-class range.  The 5 kg storage limit, or 11 US pounds, would be enough for about 10 I-class motors.  The caveat of covering black powder is a bonus, when compared to the US where no exemption for black powder exists in current regulations.  The current US exemption of 62.5 grams for APCP, when compared to the UK's new 1,000 gram limit, seems insignificant.

The UKRA extends their thanks to John Harvey of Southern England Rocket Fliers (SERFS), who represented model rocketry enthusiasts alongside UKRA's Simpson in the efforts with HSE, as well as Richard Brown, who served to clarify several issues with both HSE and UKRA.  The UKRA Safety and Technical Committee members include Richard Osborne, Colin Rowe, Rick Newlands and Charles Simpson.

Website: http://www.ukra.org.uk/

UKRA's Colin MacLaren contributed to this story.

01-25-2008 05:55 PM  #1
Steve_Shannon Will fly beer for rockets   Joined: Aug 2006 Posts: 1657	Re: UKRA gains remarkable regulatory relief from HSE agency Congratulations to our British cousins. Every foot of progress elsewhere may eventually help us by revealing the fallacy behind useless regulations.

01-25-2008 09:23 PM  #2
Aphyle Hot HCl and rubber @ AM   Joined: Dec 2006 Posts: 103	Re: UKRA gains remarkable regulatory relief from HSE agency Really good news. And this from another country that has seen significant terrorist attacks. Can our policy makers listen now? Hopefully, this information has been distributed much more widely that just RP. Maybe, just maybe...dare one hope?

01-25-2008 09:34 PM  #3
ddmobley Administrator   Joined: Jul 2006 Posts: 2146	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: Hopefully, this information has been distributed much more widely that just RP. Maybe, just maybe...dare one hope? I know what you are driving at, but I wonder as well. Apparently there are those who would rather lose the lawsuit rather than accept an exemption up to a certain level. Judge Walton is in a terrible position — to do the right thing would be career suicide and not likely to stand in post-9/11 America. We win the lawsuit, and APCP regulation then moves to HSA? That would be a terrible outcome for us, where a compromise such as the one the UK fliers negotiated could salvage 80% of our hobby.

01-25-2008 10:15 PM  #4
Aphyle Hot HCl and rubber @ AM   Joined: Dec 2006 Posts: 103	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: We win the lawsuit, and APCP regulation then moves to HSA? If it gets to HSA, then any information that is used to make a regulatory decision can be redacted from the administrative record and kept secret by the simple claim of "executive privilege." A quick search of executive privilege suggests that cases of national security, whether real or imagined, are where such claims have been upheld in court. And if you can't use government data to show the government is acting in an arbitrary fashion, it does not matter if you are right. This is what EPA is doing to California on the decision to deny California's waiver request for CO2 emissions. EPA denies a waiver over its own scientists recommendation to grant it, and then withhold records from Congress and the public on how it made the denial decision. EPA claims that releasing the records could cause experts to be reluctant to work with EPA. And where is the national security concern here? Should EPA regulate HCl emissions from rocket nozzles? Oh, I get the statement title - "Hobby Rockets could contribute to acid rain" - coming in some future EPA report. Far-fetched? Perhaps not, given this long, long saga. Getting tired of holding my breath...

01-25-2008 10:40 PM  #5
denverdoc Rana sapiens   Joined: Aug 2007 Posts: 1738	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: ...Getting tired of holding my breath... Me too, but w/o the EPA and all its faults, you would likely be wanting to hold your breath.... Lets not forget the good in regulation. It wasn't a sudden burst of social consciousness on the part of car makers and petrochemical industry that the air is still breathable. Its a dance with the devil, but until the real costs of pollution show up in the tally sheet, don't count on self regulation to take care of the problem. Rocket regulation OTOH serves no public interest I can discern, and is more about self aggrandizement of the agencies involved and paranoia than public service. What we absolutely agree on is the need for transparency in all gov't dealings which has all but disappeared since 9/11.

01-25-2008 11:14 PM  #6
Aphyle Hot HCl and rubber @ AM   Joined: Dec 2006 Posts: 103	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: Me too, but w/o the EPA and all its faults, you would likely be wanting to hold your breath.... Lets not forget the good in regulation. It wasn't a sudden burst of social consciousness on the part of car makers and petrochemical industry that the air is still breathable. Its a dance with the devil, but until the real costs of pollution show up in the tally sheet, don't count on self regulation to take care of the problem. Rocket regulation OTOH serves no public interest I can discern, and is more about self aggrandizement of the agencies involved and paranoia than public service. What we absolutely agree on is the need for transparency in all gov't dealings which has all but disappeared since 9/11. Please don't get me wrong - I agree with you completely about breathable air and the potential for self-regulation by certain industries. And EPA is denying California the right to keep the air from getting worse that it is, not to relax any standards. Why else would auto industry execs visit the VP just before the EPA denied California's request. Can there be self-regulation where there is significant economic interest involved? No, but this is where government needs to step in. Otherwise, the argument that people would worry about cars that had seat belts were somehow unsafe would hold sway. I am no tree-hugger, but I appreciate the long term efforts that EPA has made in the past, and the successes it has achieved, through regulations that are clearly in the public interest. No, I am only making an observation on the state of some of the executive branch agencies under the current administration, where public service certainly does not always take the front seat, but as you say, self-aggrandizement and paranoia do. So I don't see any disagreement with you, just a different tack.

01-25-2008 11:36 PM  #7
ddmobley Administrator   Joined: Jul 2006 Posts: 2146	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: If it gets to HSA, then any information that is used to make a regulatory decision can be redacted from the administrative record and kept secret by the simple claim of "executive privilege." A quick search of executive privilege suggests that cases of national security, whether real or imagined, are where such claims have been upheld in court. And if you can't use government data to show the government is acting in an arbitrary fashion, it does not matter if you are right. And who do you think knows this better than Washington, D.C.? Believe me, the U.S. Goverment will get the results it wants and a bunch of adults playing with kid toys be damned. The reality is we may never get that far. We have a complete deadlock currently in a no-win situation for the leader of the band. Walton may not be someone who normally goes with the flow, but the man is not an idiot by any stretch of the imagination, and not likely to buck the system merely for the pleasure of giving us a win. It would set too many dangeous precedents whereby every item on the List of Explosives would suddenly find itself open for attack.

01-25-2008 11:44 PM  #8
Aphyle Hot HCl and rubber @ AM   Joined: Dec 2006 Posts: 103	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: It would set too many dangerous precedents whereby every item on the List of Explosives would suddenly find itself open for attack. Which is why we need to be prepared for legislative relief and public information campaigns. If black powder can have a special-purpose exemption (for muzzle-loading and period firearms), why (other than the fact that rocketeers are far outnumbered by muzzle-loaders) can we not drive for the same? That, or some compromise such as the one now in the UK.

01-25-2008 11:54 PM  #9
ddmobley Administrator   Joined: Jul 2006 Posts: 2146	Re: UKRA gains remarkable regulatory relief from HSE agency To "be prepared" or to come up with "some compromise such as the one now in the UK," we would have to have alternative plans. Anyone looking at the current situation can not see evidence of any alternative plans. None. When someone suggested a compromise like what was recently worked out in the UK on another email list, the response from some was that they flew motors larger than that, so hold out for all or nothing. Rather than to possibly get something, it was better to gamble it all and possibly get nothing. I do not subscribe to the theory that to search for alternative suggests a sign of weakness, that we are not committed to the lawsuit. But it is a foolish man who puts all of his eggs in one basket and this hobby is no better. We should demand of our leadership to diversify our options or find leadership that will better protect our hobby.

01-26-2008 01:40 AM  #10
denverdoc Rana sapiens   Joined: Aug 2007 Posts: 1738	Re: UKRA gains remarkable regulatory relief from HSE agency So again why aren't we pushing hybrids. If I had the choice of an ISP of 240 or nothing--I'd ask whether I could use my own breath as in a peashooter, maybe ISP=35 if it was the choice between that and zero. The smart move is to bet almost all you own if it means survival, with a cheap hedge bet in your back pocket. Hybrids are that.

01-26-2008 04:04 AM  #11
robhouse New Member   Joined: Jan 2008 Posts: 1	Re: UKRA gains remarkable regulatory relief from HSE agency The website for the United Kingdom Rocketry Association can be found at http://www.ukra.org.uk (Typo in article)

01-26-2008 10:50 AM  #12
ddmobley Administrator   Joined: Jul 2006 Posts: 2146	Re: UKRA gains remarkable regulatory relief from HSE agency Duly noted (and corrected).

01-26-2008 09:33 PM  #13
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 570	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: It would set too many dangeous precedents whereby every item on the List of Explosives would suddenly find itself open for attack. The dangerous precedent already set are the RULINGS entered AGAINST the BATFE. We have a right to pray for a ruling and relief. The fact NAR and TRA have not expeditiously done that is telling of their motives and motivation. They have made every possible error or intentional act of industry self-destruction leading to the lawsuit and where we are, why would we not simply conclude that is likely to continue now? Perhaps it is now time to do a "Friend of the court brief" by "interested parties" who wish TRA and NAR well, but based on 15-20 years of history simply have no faith of successful behavior. That is one strategy neither the BATFE noe the executive branch expects and is the only path likely to seek a just outcome faster and better. Besides releasing a few hundred folks from jail over this would certainly get the public's attention. In a big-ass hurry. Just Jerry

01-27-2008 12:22 PM  #14
rcktnut NAR #76531-L2   Joined: Oct 2007 Posts: 35	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: I know what you are driving at, but I wonder as well. Apparently there are those who would rather lose the lawsuit rather than accept an exemption up to a certain level. Judge Walton is in a terrible position — to do the right thing would be career suicide and not likely to stand in post-9/11 America. We win the lawsuit, and APCP regulation then moves to HSA? That would be a terrible outcome for us, where a compromise such as the one the UK fliers negotiated could salvage 80% of our hobby. It has been 5 or 6 years so I'm sure my recollection here is not 100% accurate. After 9/11 I believe a substitute S.724 bill was intruduced by Kohl/Hatch that would have allowed motors with 1lb. of propellant to be exempt from any regulation. I believe that NAR/TRA went along with it a bit and then tried "tweeking" it and it died or just got absorbed into the all or nothing lawsuit?????? That was basically allowing easy access + a few 54mm. J's to be used. Myself as well as some other members of our club have been holding off on obtaining personal LEUPs' awaiting the out come of the lawsuit. Well we have finally given up on that. Now that club LEUPs' are possible we WILL be obtaining our club LEUP and storage. It will be an added pain in the butt/cost that no one in our hobby should have to go through, but we want to move on. All we have achieved with the now decades old lawsuit is more regulation at a cost of thousands and thousands of dollars. Untill 10/06 I believed there was some hope of regulatory relief, but now believe that we will lose the lawsuit or be fighting it for the next 50 years or so. I think working on a compromise would be more fruitfull, at least to allow an individual to achieve L2 without any regulation. One of our local fields can handle up to K impulse motors, one H motors, we have waivers to 8,000 ft., but have to travel 90 miles to launch the bigger ones. As with any club not all members can make scheduled launches. Then there is the weather factor. So with a compromise a few individuals could go out on a nice weekend to a local field without the club LEUP holder/magazine, and launch something bigger than a 62.5 gram motor. H and I or small Js are fun, not to many of us can afford to launch the big ones all the time anyway. Having easy access back would be fine with me and I know there would be alot of newcomers into the hobby, or the ones stuck in mid power and model, to take that first step into high power. We would also get the vendors back that we lost after 10/06 Jeff

01-27-2008 12:52 PM  #15
ddmobley Administrator   Joined: Jul 2006 Posts: 2146	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: All we have achieved with the now decades old lawsuit is more regulation at a cost of thousands and thousands of dollars. Don't look at it that way. We would have just blown those several hundred thousands dollars ourselves on silly rocket stuff.

01-28-2008 11:55 AM  #16
UncleVanya   Joined: Sep 2007 Posts: 1468	Re: UKRA gains remarkable regulatory relief from HSE agency I had a long conversation with a former HPR motor dealer this weekend. The dealer and I talked about how the loss of easy access had crushed the "impulse" buys that people made. No pun intended. The point is that having the ability to have dealers on site with motors that you do not have to pre-order would help the dealers and the consumers.

01-28-2008 12:14 PM  #17
Steve_Shannon Will fly beer for rockets   Joined: Aug 2006 Posts: 1657	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: I had a long conversation with a former HPR motor dealer this weekend. The dealer and I talked about how the loss of easy access had crushed the "impulse" buys that people made. No pun intended. The point is that having the ability to have dealers on site with motors that you do not have to pre-order would help the dealers and the consumers. Whether the pun was intended or not, it was a good one. Your point about spontaneous sales is exactly right. I worked retail for eight years before returning to school to become an engineer. Our mantra was "See it; Like it; Buy it!" How often have you been at a launch and seen something take off and asked your buddy next to you "What was that? I gotta get one!" The roadblocks that ATF created to on-site sales severely wounded the industry that serves our hobby.

01-28-2008 03:32 PM  #18
Just Jerry Freeform rockets advocate   Joined: Aug 2006 Posts: 570	Re: UKRA gains remarkable regulatory relief from HSE agency Quote: I had a long conversation with a former HPR motor dealer this weekend. The dealer and I talked about how the loss of easy access had crushed the "impulse" buys that people made. No pun intended. The point is that having the ability to have dealers on site with motors that you do not have to pre-order would help the dealers and the consumers. I think I mentioned that (a few times) when Aerotech, Magnum, and Tripoli TMT started demanding ATF permits for motor sales and manufacturers in about 1992 or so. Just Jerry

02-01-2008 04:49 PM  #19
Seany Boy New Member   Joined: Jan 2008 Posts: 1	Re: UKRA gains remarkable regulatory relief from HSE agency Sean O'Neill UKRA 1096 L3 RSO EDITOR of 10...9...8... (The United Kingdom Rocketry Association magazine.} Hi Folks. Great news for us ROCKETEERS over here. The regulations and paperwork involved since 9/11 never mind the astronomical inflation in fees to gain all our paper work were horrendous. The paperwork was so complex you needed a degree to figure it out, and once figured out it was ludicrous to say the least. . Not having vendors at some of our launches and not being able to buy or transport the motors before hand ( unless you had paid the fees, which in turn makes the hobby expensive) how are you meant to fly????????? I for one is happy now. Well done and our thanks to Charles Simpson and anyone else involved. Do any af you have any interesting articles or pics I can publish on this side of the pond in our mag? I will send a complimentary mag to you. As you can appreciate being a "small island" we dont have many members and I struggle putting the mag to print sometimes. e-mail.... This email address is being protected from spam bots, you need Javascript enabled to view it Thanks very much. Sean