[RocketsNW] IGNITERS

[Paul Bogdanich]

At 11:27 AM 4/7/2009 -0700, you wrote:  "...there's likely no basis for 
regulating an ignitor which is used with a non-explosive device.  Igniters 
packaged with unregulated motors (and replacement ignitors) were themselves 
considered unregulated."

	I think you said it in your e-mail when you said igniters, "packaged with 
unregulated motors..."  The only problem being that said devices are, in 
the opinion of some, very low performance devices so much so as to be just 
barely functional.  People of this opinion would point to all the chuffing 
and recycling one witnesses at almost any launch.  Such devices (total 
calorific output of less than .5 kcal) probably do qualify as "motor 
starters" and may very well be able to be unregulated.  I certainly don't 
see why they should be regulated as some safety match heads with the 
pyrogen scraped off, dissolved in a solvent and cast around a bridge wire 
would produce more heat.  We don't regulate books of matches do we?
	I myself, however, would like to see an "igniter" that can add between 6 
and 10 calories per cc of propellant surface, generate enough gas products 
to put the motor interior at >= 200 psi but < 400 psi, totally burn well 
within 100 ms, and achieve a flux rate of greater than 100 cal/cm2/sec for 
a 38mm motor (this last metric can change with motor size and propellant 
characteristics).  That's an igniter and I think you're still going to need 
a permit for those.  A NASA Standard would be an example of such an igniter 
albeit for a much larger motor than a 38mm.
	Whether or not a thermite (where such term includes thermate and 
thermalite) based igniters should be restricted is an open question as 
those lie between the two classes of devices already mentioned (they 
generally do not pre-pressure the motor nor create a shock wave).  I 
suspect however, that the BATFE position would be that thermite, thermate 
and thermalite are definitely regulated as they are included in the 
definitions section of the statute whereas APCP was not.