10 replies to this topic

[Boffin]

I tried asking my local explosives liaison officer but he won't give me a straight yes/no answer. I would appreciate it if someone can point me to an authoritative source that can confirm if:

1) KNO3/sugar propellants are not classed as an explosive, and therefore exempt from requiring the user to get an explosives license.

2) A rocket that has a signalling device (high vis dye, magnesium flares, or pyrotechnic composition etc.) is not classed as a Section 5 prohibited weapon.


c.f.

Manufacture and Storage of explosives Regulations 2005 ( issued by the Health and Safety Executive)

LICENSING AND REGISTRATION REQUIREMENTS (EXPLOSIVES)

456 A licence is required for most maufacturing activities

457 Manufacturing includes processes where explosive articles or explosive substances are made or assembled. Regulation 9 gives advice on what activities are considered NOT to be manufacturing

Regulation 9.

1) Subject to paragraph (2), no person shall manufacture explosives unless he holds a licence for the manufature and complies with conditions of that licence.

2) paragraph 1 (above) shall not apply to:

a) the manufacture of explosives for the purpose of laboratory analysis, testing or demonstartion or experimentation ( but not for practical use or sale) where the total quantity of explosives being manufactured at any time does not exceed 100 grams, but nothing in this sub-paragraph shall be taken as authorising any acquistition or keeping of explosives for which an explosive certificate is required by virtue of regulation 7 of those regulations, without a certificate. ( eg: smokeless or shooters powder by firearm or shotgun certificate holders)

"manufacture" includes

a) in relation to explosive articles, their repair, modification, disassembly or unmaking.
b)in relation to explosive substances, their reprocessing, modification or adaptation.

Regulation 12

A Health and Safety License is required:-

(a) For the manufacture of all explosives.

HOME OFFICE FIREARMS LAW ( GUIDANCE TO THE POLICE)

Authorities under section 5 of the 1968 Act

3.20 Before a decision is made concerning a particular application for an authority the chief officer of police in the area from which the application has been received will be asked if they have any objections to the grant of the authority. If an authority is granted, it will be sent to the applicant and copied to the chief officer of police. As a matter of policy, the Secretary of State would normally only grant authorities to for those with a legitimate commercial need to possess prohibited weapons, rather than for private use or speculative business interest. The chief officer will be informed of any case which an authority is refused or
revoked.

Prohibited weapons include:-

3.2. vi) any rocket launcher, or any mortar, for projecting a stabilised missile, other than a launcher or mortar device designed for line-throwing or pyrotechnic purposes or as a signalling device.

vii) any weapon of whatever description designed or adapted for the discharge of any noxious liquid, gas or other thing.

x) any rocket or ammunition not falling within (viii) above which consists of, or incorporates, a missile designed to explode on or immediately before impact and is for military uses .

vii any cartridge with a bullet designed to explode on or immediately before impact, any ammunition containg or designed or adapted to contain any such noxious as is mentioned in ( viii ) above and if capable of being used with a fiream of any descritption, any grenade, bomb or other like missile, or rocket or shell designed to explode as aforesaid.

[exat808]

My view is that firstly you must establish how the legislation interprets your rockets/propellants. The only definitive test will be for you to submit your product in an approved package to the HSE and get it classified. Once classified under the UN system you will then have a start point for all matters relating to transport and storage etc.

Looking at Section 5 of the Firearms Act there are many subsections of this that may be applicable to what you are anticipating. Your quote regarding line throwers and signalling devices is correct but if you are speculating on such the production of such a device then I would suggest that you contact the Home Office Public Protection Unit and seek some further advice based on your designs.

There are many people out there who have developed novel defence ideas but who have fallen foul of the law.

Edited by exat808, 21 June 2010 - 09:18 PM.

[Boffin]

My view is that firstly you must establish how the legislation interprets your rockets/propellants. The only definitive test will be for you to submit your product in an approved package to the HSE and get it classified. Once classified under the UN system you will then have a start point for all matters relating to transport and storage etc.

Looking at Section 5 of the Firearms Act there are many subsections of this that may be applicable to what you are anticipating. Your quote regarding line throwers and signalling devices is correct but if you are speculating on such the production of such a device then I would suggest that you contact the Home Office Public Protection Unit and seek some further advice based on your designs.

There are many people out there who have developed novel defence ideas but who have fallen foul of the law.

Thanks, I will speak to the Explosives Inspectorate at the HSE and the Firearms and Explosives Section at the Action against Crime and Disorder Unit of the HO to get further details.

[digger]

Yes KNO3/Sugar propellant is an explosive in the eyes of the law. As already stated if you are intending to produce devices for sale you will need to obtain a HSE licence to produce them. To then be able to sell them they will need to be classified and you will have to then have approved shipping containers (boxes) produced and tested. You will need planning permission for the manufacturing site also.

If you are doing this from an amateur perspective you can use MSER to produce up to 100g of propellant for experimental purposes. But packing this in a tube may well break the law, although MSER would read like you could do this the HSE have stated that they consider this to be illegal. There have been no test cases on this point as far as I am aware.

The experimentation rule does not in any way authorise the storage or transportation of the compound from the experimental environment.

Regarding the rocket as a weapon issue. It would be best to contact some of the rocketry clubs such as EARS (East Anglian Rocketry Society). I believe the upshot is that a rocket become a stabalised missile when a guidance system is attached to stabilise flight (or obviously if you stick a warhead on it).

[Boffin]

Thanks for your informative post.

Yes KNO3/Sugar propellant is an explosive in the eyes of the law. As already stated if you are intending to produce devices for sale you will need to obtain a HSE licence to produce them. To then be able to sell them they will need to be classified and you will have to then have approved shipping containers (boxes) produced and tested. You will need planning permission for the manufacturing site also.

KNO3/sugar an explosive? Here's a clip of it burning:

KNO3/sugar burn test

Anyway, it appears the jury is still out. The HSE said they are making inquiries to ascertain the classification of KNO3/sugar.

If you are doing this from an amateur perspective you can use MSER to produce up to 100g of propellant for experimental purposes. But packing this in a tube may well break the law, although MSER would read like you could do this the HSE have stated that they consider this to be illegal. There have been no test cases on this point as far as I am aware.

Do you have a contact email for the "The Home Office, Firearms and Explosives Section, Action against Crime and Disorder Unit" for me to address my Section 5 weapons enquiries to? Snailmail is too slow and I want everything in writing.

The way I'm thinking, as amateur rockets with off-the-shelf rocket motors are not Section 5 weapons, a homemade rocket with a DIY rocket motor is not a Section 5 weapon as well, but the law can be an unpredictable beast, and the stakes are high here.

The experimentation rule does not in any way authorise the storage or transportation of the compound from the experimental environment.

Does that mean I must cast the experimental propellant grains at my launch site?

Regarding the rocket as a weapon issue. It would be best to contact some of the rocketry clubs such as EARS (East Anglian Rocketry Society). I believe the upshot is that a rocket become a stabalised missile when a guidance system is attached to stabilise flight (or obviously if you stick a warhead on it).

EARS rockets appear to be low performance ones with plastic casings (metal ones are not allowed as per their UKRA code of safety) or using off the shelf rocket motors.

The rocket I have designed uses a metal casing for higher chamber pressures, a high efficiency De Laval nozzle but off-the-shelf subcomponents throughout, resulting in a rocket with decent performance at low cost.

[digger]

Thanks for your informative post.



KNO3/sugar an explosive? Here's a clip of it burning:

KNO3/sugar burn test

Anyway, it appears the jury is still out. The HSE said they are making inquiries to ascertain the classification of KNO3/sugar.

I understand your point, but I have seen CAD apps for smoke devices and the smoke generating component is clearly defined as a pyrotechnic/explosive substance. This burns even less fiercely.

I am almost certain it will be considered an explosive substance as one initiated it has a self sustaining reaction not requiring atmospheric oxygen. It produces a pyrotechnic effect in that it generates heat, smoke, light and thrust.

[font="Arial"]Do you have a contact email for the "The Home Office, Firearms and Explosives Section, Action against Crime and Disorder Unit" for me to address my Section 5 weapons enquiries to? Snailmail is too slow and I want everything in writing.

The way I'm thinking, as amateur rockets with off-the-shelf rocket motors are not Section 5 weapons, a homemade rocket with a DIY rocket motor is not a Section 5 weapon as well, but the law can be an unpredictable beast, and the stakes are high here.

Nope I don't have a direct contact. I think you may be getting a little hung up on this. I guess if you are talking about a commercial device this will be dealt with by authorising it as hobby rocket motor though the HSE after you get a manufacturing licence.

[font="Arial"]
Does that mean I must cast the experimental propellant grains at my launch site?

Technically you would be pushing the bounds of the law just by putting the grain in the casing, let alone transporting an unclassified device (definitely illegal.

[font="Arial"]
EARS rockets appear to be low performance ones with plastic casings (metal ones are not allowed as per their UKRA code of safety) or using off the shelf rocket motors.

The rocket I have designed uses a metal casing for higher chamber pressures, a high efficiency De Laval nozzle but off-the-shelf subcomponents throughout, resulting in a rocket with decent performance at low cost.

We had our AGM at an EARS event a couple of years ago. I am pretty certain they were launching some big high power stuff there judging by the thump of what I can only assume were bursting disks breaking on AP motors as they were fired.

mmm DeLavl Nozzles, I have designed loads of them (Steam Ejectors)

Edited by digger, 24 June 2010 - 01:37 PM.

[Boffin]

I understand your point, but I have seen CAD apps for smoke devices and the smoke generating component is clearly defined as a pyrotechnic/explosive substance. This burns even less fiercely.

I am almost certain it will be considered an explosive substance as one initiated it has a self sustaining reaction not requiring atmospheric oxygen. It produces a pyrotechnic effect in that it generates heat, smoke, light and thrust.

Well, this is confirmed. The HSE said KNO3/sugar is an explosive substance

Do the HSE have authoritative power to define what an explosive is by law, or does basically no one in their right mind want to challenge their interpretation of the law of what defines an explosive in court, because the stakes are so high if they lose?

Nope I don't have a direct contact. I think you may be getting a little hung up on this. I guess if you are talking about a commercial device this will be dealt with by authorising it as hobby rocket motor though the HSE after you get a manufacturing licence.

Are these authorisations done on a per motor design basis or to the individual designing the rocket motor?

Technically you would be pushing the bounds of the law just by putting the grain in the casing, let alone transporting an unclassified device (definitely illegal.

Silly question but why doesn't one of the most popular solid fuel for amateur rocketry not have a UN classification?

mmm DeLavl Nozzles, I have designed loads of them (Steam Ejectors)

Crucial in rocket design as they convert some of the thermal energy of the exhaust into kinetic energy. Without them we'd be looking at hot, wasteful exhaust.

Edited by Boffin, 25 June 2010 - 12:12 AM.

[digger]

I think you would have a very hard time trying to say that KNO3 sugar is not an explosive. I would not try to fight that one. It would be way more expensive than setting up a factory and you would lose.

The Authorisation would be done for the design so that you could then, classify, manufacture transport and sell them. If you are going to do this then you may as well classify many designs in one go. This may not be as easy as you think, You may need to do bonfire testing and if it is going to be a consumer product (rather than proffesional) then you will probably have to have it CE tested.

UN numbers, I would guess that all motors that can be purchased will have a UN classification (it is needed to transport them) eg 1.2 . If you are talking about the chemical in the fuels then this too has its own UN number too.

[Boffin]

I think you would have a very hard time trying to say that KNO3 sugar is not an explosive. I would not try to fight that one. It would be way more expensive than setting up a factory and you would lose.

OK.

May I ask if nitrocellulose, nitroguanidine or other smokeless energetics for use in firearms classify as propellants and are therefore exempt from explosives licensing requirements?

I had thought about using such smokeless propellants to get better efficiency by avoiding two phase flow flosses (precipitated potassium salt solids + hot gases) characteristic of rocket candy, but ironically thought they would be harder to acquire and license than rocket candy. AIUI it is not a legal requirement to display any licenses to buy such propellants, although most gun shops (I'm told) ask for a FAC to sell you the propellant.

The Authorisation would be done for the design so that you could then, classify, manufacture transport and sell them. If you are going to do this then you may as well classify many designs in one go. This may not be as easy as you think, You may need to do bonfire testing and if it is going to be a consumer product (rather than proffesional) then you will probably have to have it CE tested.

Well, if the license applies to the design then yes, you're right that I may as well get them authorised to be able to manufacture, transport and sell them.

What constitutes a substantive change in the design such that a new authorisation is required? The design process will be iterative - I want to try different propellant grain geometries/masses, spin stabilisation, De Laval nozzle configurations, etc.

UN numbers, I would guess that all motors that can be purchased will have a UN classification (it is needed to transport them) eg 1.2 . If you are talking about the chemical in the fuels then this too has its own UN number too.

OK thanks. I fired off (excuse the pun!) more questions to the HSE about the legalities and hope to hear back from them soon*

Also...I was wondering whether I should ask this but how is it some of you here seem to know so much about me? Have you been comparing notes about the newcomer?


*Edit: I just got a response from them and was told they had to forward my enquiries to the explosives inspectorate, and I should expect a reply in a few days.

Edited by Boffin, 25 June 2010 - 07:04 AM.

[digger]

The other propellants that you mention are explosives and are classified as such. You need a COER certificate to get them. Then the exemption only applies for use as shooters powders. Again if you put them into a case it would be a new pyrotechnic device. So the only option for a self sustaining motor design is through a manufacturing licence. The only option open that may not go down this route would be with composite motors (lOx, NOx).

If you had a manufacture licence then you could play to your hearts content getting your motor right before you classified it for transport. As during your licence application you will have designated a testing area at your factory. I know we are glibly talking about manufacturing licenses, it is not that easy to get one. You will need a suitable site, draw up plans in accordance with MSER pay the money and here is the kicker get planning permission (very difficult)

No idea what you are on about regarding "how is it some of you here seem to know so much about me"

Edited by digger, 25 June 2010 - 07:29 AM.

[Boffin]

The other propellants that you mention are explosives and are classified as such. You need a COER certificate to get them. Then the exemption only applies for use as shooters powders. Again if you put them into a case it would be a new pyrotechnic device. So the only option for a self sustaining motor design is through a manufacturing licence. The only option open that may not go down this route would be with composite motors (lOx, NOx).

If you had a manufacture licence then you could play to your hearts content getting your motor right before you classified it for transport. As during your licence application you will have designated a testing area at your factory. I know we are glibly talking about manufacturing licenses, it is not that easy to get one. You will need a suitable site, draw up plans in accordance with MSER pay the money and here is the kicker get planning permission (very difficult)

I'm a self-employed scientist working out from my living room at home in a residential area. I do have access to explosives and gun ranges, but the former cost a king's ransom to lease to use. MoD ranges for the latter have restrictions on what can be shot at/with (targets/firearms) but I am making enquiries with the private gun ranges what they can use (e.g. if they allow black powder firearms then presumably they allow explosives on site).

I guess the crux of my question is whether I go about an amateur rocketry interest with my own DIY motors in the UK. By this I mean playing with different propellant chemistries, casting the propellant grains in the kitchen and firing them in a suitable location.

Moving countries is an option for me...I always wanted to experience other cultures/see other places, although I'd prefer a country with a Christian tradition.

No idea what you are on about regarding "how is it some of you here seem to know so much about me"

Alright, perhaps I'm wrong but your suggestion to check out EARS was spot on (they are in my neighbourhood) and reading between the lines your assumption of my intention to build/test/sell the products were also spot on.