As I mentioned on the mailing list, I’ve attached a copy of the CA “Fireworks Handbook 2011″ from the CA OSFM web site.  It brings together all of the CA laws and regulations covering fireworks (and rockets) in one place.

Here it is: FireworksHandbook2011.pdf

I’m making it my project to go through this 187-page book, identify all of the parts that deal with rocketry of any variety, and annotate what I see as problems with the way it’s currently written, and how I’d like to see it changed.  I’ve only just begun, but I’ve attached that document, as well, so you can at least see where I’m headed with it.

Here’s the start of my document: ProblemsWithCurrentLawsAndRegulations.doc

I’d appreciate as much help as I can get with this effort.  I’ll be happy to collect all of the suggestions, and combine them all into a single document, but I don’t relish the thought of doing it all by myself (plus, I’m sure that I’ll miss things, and won’t necessarily have the same viewpoint as everyone else, so additional eyes and perspectives will be helpful).

Feel free to email me your suggestions and comments directly, add them as comments to this blog post, or send them to the mailing list.  I’ll collect them from wherever they come, and combine them into this one document.

My personal goals and motivations for any re-write of the laws and regulations are:

  1. Eliminate any and all EXTRA burdens that California imposes on rocketeers, over and above those that exist elsewhere in the country.
  2. Avoid “hardcoding” limits and technologies based on the current situation.  Technologies change, best practices change, and the hobby, as a whole, changes over time.  Our laws and regulations have to be flexible.  (For instance, if we refer to NFPA codes, we should ALWAYS refer to the current OR LATER EDITION, rather than limiting ourselves just to the current version.)
  3. Eliminate any and all extra burdens that California imposes upon manufacturers, importers, exporters, wholesalers, and retailers, over and above those that exist elsewhere in the country.
  4. As much as is possible within the regulatory framework, defer to the expertise and authority of the various national rocketry organizations.  As one example, rather than requiring the CA OSFM to “classify” all rocket motors as model or high power rocket “engines”, accept certification as model or high power rocket motors by NAR, TRA, or CAR as an alternative.  As another, rather than requiring PyroOp/Rockets licensing for HPR flyers, accept NAR/TRA/CAR flyer certification as an alternative.

Cheers,

- Rick Dickinson

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More from Mary Roberts:

All,
More state laws exempting model rockets from fireworks legislation.  One
or more of these would be useful for "code writing". The remainder of the
code writing work would be to delete references to model rockets and model
rocketry in other parts of the code.

The laws might also be helpful to review with legislators.   It might
assure them that model rocketry does not require extensive legislation and
can be well regulated using the appropriate NFPA Codes.
Kind Regards,
Mary Roberts
Estes-Cox Corp.
1295 H Street, PO Box 227
Penrose, Colorado 81240 USA
+1 719 372 6565 x 273
+1 719 372 3419 Fax
mroberts@centurims.com
www.estesrockets.com

 

GA ModRoc Law-2010.doc

ModRocLaw-OH.doc

ModRocLaw-OR.doc

ModRocLaw-WV.doc

WA ModRoc Law Chapter 212-12.doc

 

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Here’s some more info from Mary Roberts:

All,
Attached is an example of a state law that simply exempts model rocketry
from fireworks, Texas.  Will send more later.
Mary

ModRocLaw-TX.doc

 


                                    
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Here’s some more background information from SCRA Vice-President Fred Shecter, from an email originally sent to NAR President Trip Barber:

 

Trip,

Thanks for all the efforts.

I had been in contact with John Kitchens via e-mail but he
went "radio silent" in early 2011. We then were relying on
the other Fire Dept contact in San Diego who was going to
draft the proposed revisions to the Model Rocket
regulations, but his supervisor wanted him to review and
revise ALL of the fireworks regulations if he was going to
do any work on them whatsoever. So, he put that on a back
burner (and turned the burner off...).

See the attached document where I copied and pasted some e-
mail exchanges from the past year. You'll see my exchanges
with Anthony (Tony) Guevara of the CSFM office starting at
the bottom of the document. After that seemed to reach a
semi-dead end, I posted a message on our NAR Section's
YahooGroup to ask if anyone had a relationship with their
State Senator or Assemblyman. One person (Gregg Halligan)
responded and I told them I would get back in touch with
them once we had an idea of what we changes we would
propose.

Then Ryan Coleman made contact in an attempt to get things
moving again. I forwarded the message from Gregg to Ryan and
we did a bit of e-mail discussions. I agreed to whip up a
document (second attachment) that details what I think needs
to be revised in the Health & Safety Code as well as the
Regulations. He has initiated contact to discuss that as you
can see in the e-mails at the top of the first attachment.

I am willing to do whatever I can do. I am concerned that
the the regular revision process to the Regulations will
take 3 years but that can only happen if the committee meets
to work on those revisions and they have allegedly not met
in many, many years. And then the regulations will still be
invalid as the Law (Health & Safety Code) would still
explicity prohibit metal casings, handling propellant (even
if pre-cast in segments), and maintain the 500 gram weight
limit.  If the proper fireworks committee can propose
revisions to the Regulations and then those revisions would
drive a change to the Health & Safety Code through some
process not yet explained to me, then that would be semi-
encouraging.

Look over the attachments and let me know what you suggest
we do next. I can boil my second attachement down to a .ppt
presentation and send it to John and see what he thinks of
it.

-Fred Shecter

 

I’ve attached the files referred to in the email:

emails-CA-Laws-Regs.doc

Proposed_revisions_HScode.doc

CSFM-2010-09-23-Model-rockets-and-metal-casings.pdf

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Here’s an excerpt from a message sent by Mary Roberts at Estes:

 

Previous fire marshal personnel have not interpreted California law as
strictly as Tony's group.  They have previously classified G motors and
reloadables as model rocket motors.  They have not requested periodic
reports from manufacturers and they have not enforced the 500 gram
limit.  And they adopted as much of NFPA 1122 as they could within the
constraints of the law.  I'm not certain what occurred to change that.

If they must interpret the law as is and as they have recently been
doing, then they don't have much leeway unless they request that the
California legislature change the law (H & S Code).  

I have attached most of the pertinent sections of the Health and Safety
Code. I may have missed a few as I didn't copy all. Some of the passages
regarding rocketry are highlighted.  I've also attached a copy of the
legislative process and listings of both California legislators and
senators should anyone be interested in pursuing legislative relief
going forward.  That may be necessary to effect change if the regulators
such as John Kitchens and Tony Guevara are unable to help. Following is
a quick link to the California legislative process site as well.

http://www.leginfo.ca.gov/bil2lawx.html 

As you have suggested possibly the best solution so far as legislative
change would be to EXEMPT rocketry from the fireworks code (state law)
and to specify that state regulators adopt the pertinent NFPA Codes. To
my knowledge California is the only state regulating rocketry as
fireworks.  

Mary

I’ve attached the files she referred to in her email.

Calif Health & Safety Code ModRoc Law-12.doc

CALIFORNIA-SENATORS-12.doc

CALIFORNIA-ASSEMBLY-MEMBERS-12.doc

Calif-Legislative-Process.doc

 

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California’s Rocketry laws and regulations are antiquated and baroque.  Written years ago, when welded steel zinc-sulfur rocket dinosaurs ruled the earth, they are a very poor match for the realities of rocketry in the 21st century.

A group of rocketeers, manufacturers, and representatives from the national rocketry organizations have come together to attempt to facilitate changes to these antiquated laws and regulations.

This web site will serve as a file repository for that effort, and as a public face for the project.  There is also a publically-available mailing list.  Sign up for that at http://www.freelists.org/list/rocketlaws-ca

 

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