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The main issue the BATFE typically has with people that have a LEUP, required to fly Regulated Hobby Rocket Motors, is their record keeping. There is much misinformation and opinions on what to do out there. There is only one correct answer, follow the requirements of the 555 section of the CFR, (Code of Federal Regulations). If you do that there will not be any issues. There are a couple of areas that focus specifically on the requirements concerning record keeping. If you follow these simple rules, you should be ok. It is highly recommended that each LEUP holder review and understand from the source, GPO Access, Code of Federal Regulations
There are two types of forms that you should be keeping. The first is the Acquisition Log. This can be accomplished in one of two ways or our recommendation, do both. You can simply keep your Vendor Receipt with all of the pertinent information required by the following sections, Date of Acquisition 555.125 (b)(3)(i), Name or Brand of Manufacturer 555.125 (b)(3)(ii), Manufacturers Marks of Identification 555.125 (b)(3)(iii), Date Shift Code 555.109, Quantity 555.125 (b)(3)(iv), Description 555.125 (b)(3)(v), Name 555.125 (b)(3)(vi), Company 555.125 (b)(3)(vi), Address 555.125 (b)(3)(vi), License Number 555.125 (b)(3)(vi). You can also create a separate log to track this information in addition to keeping your receipts. This is the recommended procedure.
Theses requirements are described as follows:
Date of Acquisition 555.125 (b)(3)(i), This is the Date on your Receipt. Technically if your Vendor puts the date you ordered the motor on the receipt and you don't pick it up for 2 months you may be considered responsible for that motor. Be sure he puts the Date you pick it up at the field on the receipt. See the example Acquisition Log forms.
Name or Brand of Manufacturer 555.125 (b)(3)(ii), This is simply either Aerotech, Loki Research, Cessoroni, Ellis Mountain, Animal Motor Works, etc. See the example Acquisition Log forms.
Manufacturers Marks of Identification 555.125 (b)(3)(iii), This is what the motor is called such as J-350, J-528, etc. See the example Acquisition Log forms.
Date Shift Code 555.109, This is something that has always been a requirement and overlooked by many people. It is a multi-digit code number that is typically located on the label of the product. Record this in its entirety. If you are unsure ask the Vendor as this should be included on his receipt information or call the manufacturer. See the example Acquisition Log forms.
Quantity 555.125 (b)(3)(iv), This is the number of the same motors with the same Date Shift Codes. For example if you bought three J-350’s on the same day and they all had the same Date Shift Code then you would enter this as 3 to fulfill this requirement. Or if you bought three J-350’s on the same day and they all had different Date Shift Codes then you would have to have three different entries to account for the different date Shift Codes. If the motors are different types such as J-350 and K-550 then they would have to be entered separately. See the example Acquisition Log forms.
Description 555.125 (b)(3)(v), This should be entered as Hobby Rocket Motor. Nothing more, nothing less. See the example Acquisition Log forms.
Name 555.125 (b)(3)(vi), This is the full name of your Vendor. See the example Acquisition Log forms.
Address 555.125 (b)(3)(vi), This is the full address of your Vendor. See the example Acquisition Log forms.
License Number 555.125 (b)(3)(vi), This is the BATFE License of your Vendor. See the example Acquisition Log forms.
All of the above information is required to be on your Vendor Receipt and it is recommended to be kept on a separate Acquisition Log. See the example Acquisition Log forms.
Special Note: The separate Acquisition Log must be recorded by hand, in pen. This considered a permanent record by the BATFE. If you would like to keep it on your computer then you have to apply for a variance with the BATFE and they will examine your computer.
The second form of record keeping is the Magazine Log. The real name of this document is the DSMT or the Daily Summary of Magazine Transactions. That is what you want to call it. It is a separate form that must be maintained as a permanent record. That means that you must hand write it and fill it out with Pen. The requirements for this document are found at CFR 555.127. They are: Manufacturer or Name Brand 555.127, Date 555.127, Amount In 555.127, Amount Removed 555.127 and Balance 555.127.
Theses requirements are described as follows:
Manufacturer or Name Brand 555.127, This is entered as by the Manufacturer of the product, regardless of the types such as I-211 and J-350, entered into the Magazine on a specific date. As an example, if you entered in three Aerotech motors, an I-211 and two J-350’s on the same day there would be only one line entry. It would say "Aerotech Hobby Rocket Motor". That is all the code requires. Anything else, no matter how well meaning and clarifying is not required and may cause you issues down the road on further inspections. See the example DSMT forms.
Date 555.127, This is the Date of the Transaction in or out. See the example DSMT forms.
Amount In 555.127, This is the total quantity of a single manufacture put in on the same day. Per the example above the one I-211 and the two J-350’s would be entered on the log as “3”. Do not enter each motor individually, regardless of how much sense it seems to make. It is wrong. If you enter different manufactures then you would use a separate line item. See the example DSMT forms.
Amount Removed 555.127, This is the total quantity of a single manufacture put removed on the same day. Per the example above of the one I-211 and the two J-350’s would be entered on the log as “3” under this column if all three were removed. Do not enter each motor individually, regardless of how much sense it seems to make. It is wrong. If you remove different manufactures then you would use a separate line item. See the example DSMT forms.
Balance 555.127, This is the running total of what is in the Magazine at any given time. This must match exactly what is in the magazine. See the example DSMT forms.
It is important to note that the purpose of these logs is to track the "Explosive". No matter what your personal opinion is concerning the technical interpretation of the word “Explosive”, be forewarned that the BATFE sees our Hobby Rocket Motors as exactly that and will enforce the requirements of CFR 555 by the book. The above listed suggestions are by the book, however the BAFTE does not subscribe or endorse to this publication or this description.
If I receive a quantity of Regulated Hobby Rocket Motors at the field and do not fly them what should I do?
You have a couple of options. 1) Pre-arrange with your Vendor to place the motor (s) back in his Magazine until the next launch date. This will require you to begin filling out your DSMT, since you are now the owner of the motor. The Vendor should be filling out his DSMT and his entries should correspond to yours. 2) Have your own pre-approved Magazine and follow the requirements above. 3) Pre-Arrange with a friend who has a Magazine and follow the requirements above. 4) Free burn the propellant at the field, (not likely).
Once you start entering motors in the DSMT you must comply with the requirements of entering motors in and removing motors per 555.127. The worst thing you can do is not to record the transactions and stay in step with the magazine owner. If the numbers are off at the next BATFE inspections both parties are responsible.
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