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Home / Archives / Letter from Transport Canada concerning high power rocketry
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Letter from Transport Canada concerning high power rocketry |
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1999 Archived News by Cesaroni Technology
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Tuesday, June 22, 1999
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GORMLEY, Ontario CAN — In recent announcement to the Canadian high power rocket flyers, Anthony Cesaroni, president of Cesaroni Technologies Incorporated released a letter from the Canadian Launch Safety Office of Transport Canada outlining their role with respect to high power rocket launches in Canada. As the letter indicates, there has been some confusion regarding the roles and responsibilities of the various organizations involved.
Mr. Cesaroni stated, "One point that I would like to make involves NFPA Codes. The National Fire Protection Association is one of many international standards organizations such as ANSI, API, ASME, ASTM, ULC and CSA. Active members of the NFPA come from all over the world and include representatives from Natural Resources Canada. NFPA is not a body of legislation but a collection of recommended standards. It has no legal basis anywhere in the world unless it has been adopted by a federal, state, provincial or municipal government. NFPA standards are recognized throughout the insurance and fire prevention industries and have made a significant contribution to the awareness of fire safety in many areas of industry and commerce. The Ontario Fire Code contains not less than 25 references to NFPA standards.
"I have read a number of emails from individuals resenting the fact that NAPAS has adopted an American regulation to conduct high power activities in Canada. Not that this should matter, however, it is clearly not the case. NAPAS submitted NFPA 1127 to Transport Canada for consideration as the standard has been successfully adopted by Tripoli and the high power industry in the United States for a number of years. Thousands of flights have been conducted under this standard and it has been accepted by major insurance underwriters. The CLSO has reviewed the standard's safety code and certification process and has stated that NAPAS members are qualified to build and launch high power rockets in Canada under the direct supervision of a qualified Range Safety Officer at an approved launch site."
The NAPAS corporate charter requires it to conduct its activities in accordance with Transport Canada and Natural Resources Canada regulations, in other words, Canadian law.
If you have any questions about Canadian regulatory issues, you are encouraged to contact a member of the NAPAS executive or technical committee. This will hopefully reduce the number of redundant questions that the CLSO and NRCED will have to deal with.
 | Transport Canada | | Transports Canada | | Civil Aviation | | Aviation civile | | Prairie and Northern Region | | Région des prairies et du nord |
P.O. Box 8550
344 Edmonton Street
Winnipeg, Manitoba
R3C 0P6
21 June, 1999
Dear High Power Rocket Enthusiast:
Recent discussions with high power rocket enthusiasts indicate some confusion exists respecting the role of the Canadian Launch Safety Office (CLSO) of Transport Canada. This letter attempts to clarify misconceptions regarding the CLSO's role in regulating rocket activity in Canada.
The Aeronautics Act and Canadian Aviation Regulations (s. 602.43 and 602.44) require the Minister of Transport to authorize all rocket launches in Canada, excepting model rockets or those used in fireworks displays, where those launches are in the interest of the public and not likely to affect aviation safety. In order to authorize a launch the Minister must, therefore, be assured that the launch and flight of the rocket will not pose unacceptable risks to the public or aviation.
The CLSO supports the Minister by providing regulatory oversight of rocket activities by conducting safety analyses of launch proposals, authorizing launch sites and monitoring launch operations for compliance with authorized activities. Over the past two years we have been in contact with many rocketry enthusiasts to discuss concerns and resolve issues regarding high power rocket launching. It is apparent from our review of the safety requirements set out by various rocketry organizations that the requirements needed updating to bring them in line with current Canadian regulations and accepted procedures. To assist users in this regard the CLSO issued the "Requirements for Launching High Power Rockets in Canada", establishing the minimum acceptable requirements to be met for approval to launch.
To ensure the requirements were relevant, fair and reasonable the document was developed by the CLSO, in consultation with high power rocketry enthusiasts and Natural Resources Canada - Explosives Branch (NRCan). The document sets out the criteria and restrictions for all persons launching high power rockets in Canada, whether or not affiliated with a rocketry organization. Everyone must adhere to these requirements when launching high power rockets in Canada. They are legally binding.
They are legally binding because they support issuance of the Canadian Aviation Document, "Rocket (High Power) Launch Authorization", by the Minister of Transport, in accordance with provisions set out in the Aeronautics Act and the Canadian Aviation Regulations. Parliament provides for the regulation of aeronautics through the Aeronautics Act and the Canadian Aviation Regulations are rules of conduct made by Cabinet on the advice of the Minister of Transport. On the other hand, the safety codes and standards set out by various rocketry associations are enforceable only upon their members or those persons participating under their oversight.
We have received calls and messages from members of associations and non-members asking what is the current process for certification and qualification to fly high power rockets in Canada. At this time, the CLSO does not have a process to ensure individuals are certified and technically qualified to fly high power rockets. The CLSO relies on associations who have acceptable procedures in place for testing individuals to ensure they have the knowledge required to build and fly high power rockets. These associations must also ensure that a qualified Range Safety Officer inspects the rocket before launch and that all launches occur from approved launch sites.
Currently there are two associations in Canada, the Canadian Association of Rocketry (CAR) and the North American Propulsion and Aerospace Society (NAPAS), who have acceptable procedures in place for certifying individuals to launch high power rockets in Canada. CAR member requirements are set out in "The Control of High-Power Rocketry in Canada". CAR certification is obtained by successfully completing an exam administered by CAR and then successfully launching a rocket, appropriate to the certification level sought. NAPAS follows the USA's Tripoli Rocketry Association certification process. Members adhere to the requirements detailed in the "High Power Rocketry Safety Code, NFPA1127". NFPA 1127 has legal basis only in the USA, not in Canada. Both organizations ensure that all launches are conducted in accordance with Transport Canada launch authorizations and requirements. The CLSO has evaluated both processes and determined that each ensures its members are qualified to build and launch high power rockets.
To ensure all high power rocketry participants in Canada are aware of Canadian requirements the CLSO will define questions, based on these requirements, for inclusion in current qualification exams. The questions will be provided to CAR and NAPAS representatives in the near future.
Confusion also is apparent regarding the division of responsibilities and authorities between CLSO and NRCan. Jurisdiction for specific high power rocketry issues is as follows:
Natural Resources Canada - Explosives Division:
- issues approvals for use of specific rocket motors (those classified as explosive),
- issues approvals for importation of rocket motors,
- issues approvals for transportation of rocket motors by road (in partnership with Transport Canada),
- issues approvals for sale of rocket motors,
- issues approvals for storage of rocket motors,
- issues approvals for Canadians to purchase and use rocket motors, and
- issues approvals for pyrotechnic igniters.
The contact for issues noted above is:
Natural Resources Canada - Explosives Division
Sir William Logan Building
580 Booth Street, 15th floor
Ottawa, Ontario K1A 0E4
Attention: Dave McCulloch, Inspector of Explosives Tel.: (613) 995-8995
or Constantin Matusoff, Inspector of Explosives Tel.: (613) 943-8278
Transport Canada - Canadian Launch Safety Office:
- defines the requirements to be met for launching high power rockets in Canada - user, launch site, airspace and safety requirements;
- responsible for monitoring compliance with authorized activities at a launch - ensuring adherence to "Requirements for Launching High Power Rockets in Canada"; and ensuring safety concerns are addressed during the preparation, launch, flight and recovery of rockets;
- reviews and analyzes information submitted pertaining to hybrid rocket motors to determine acceptability for issuance of an authorization to launch. Approval to launch a hybrid high power rocket does not in any way mean that the rocket motor is approved for sale;
- defines airspace requirements for rocket launches and arranges for airspace restrictions/advisories and issuance of Notices to Airmen (NOTAMs);
- approves launch sites for proposed launches;
- approves the acceptability of an organization's member certification/qualification programs to meet Canadian requirements for launching high power rockets in Canada; and
- approves the acceptability of the Range Safety Officer to perform the duties and responsibilities relevant to the authorized launch.
Should you have any questions or concerns you may contact Jack Ireland at (204) 984-7296 or Lavina Harding at (204) 984-7286 or by facsimile at (204) 983-2005.
Sincerely,
D.L. Warren
Manager
Canadian Launch Safety Office
cc: Dave McCulloch
Constantin Matusoff |
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