At 07:23 PM 10/12/2004 -0700, Jerry Durand wrote:
Orange Book, page 57, question 27
"27. How are airbags regulated by AFT?
Unless the product has been classified by AFT as a special explosive device and exempted from regulation under 27 CFR 55.32, an airbag device containing explosive initiators, igniters, or inflators is subject to regulation as containing explosive materials, i.e., low explosives, and must comply with all applicable requirements under 27 CFR Part 55."
OK, I found it this time, http://www.atf.gov/explarson/fedexplolaw/qanda.pdf. But it doesn't answer the question. If air bag initiators are propellant actuated devices, the above statement could be true while being completely meaningless: propellant actuated devices are exempt from 27 CFR 55, so "all applicable requirements" would be semantically equal to - not equivalent to, but *equal* to - "no requirements."
This reminds me very much of my attempts a couple years ago to find a clear, concise, unambiguous definition of "controlled airspace." What unambiguous explanations exist do not answer the question, and what explanations answer the question do so ambiguously.
Fortunately, in this job, free Motrin is an employee benefit. :-|
-R
PS I did find one thing that was unambiguous and might be applicable to ERPS, if you guys decide to bite the bullet and keep using solids for testing non-propulsion hardware: ATF says in a FAQ that explosives magazine users must inspect their magazines at least every seven days to ensure that nothing has been stolen therefrom. Makes having a magazine out in farm country somewhere no big advantage, if you have to visit it every week.
Randall Clague Government Liaison XCOR Aerospace [EMAIL PROTECTED] 661-824-4714
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