In a past life I was responsible for negotiating the technical engineering aspects of a significant subcontract. whenever we found ambiguity in the contract it was good news because we could exploit this to get more money from the prime. As a result I have a fine tuned "ambigious nit sensor". I have to fight this impulse to pick these nits when working with the FAA.
A simple example:
One of the comments I received on my draft application was :
AST understands that there are no hazardous materials asociated with the vehicle.
However for the purposes of documentation completeness, the application still needs to state positively that there are no hazardous materials used in the suborbital rocket.
Seems like a simple statement and they are really looking for a statement that I'm not using hydrazine or some other really nasty substance. This seems really simple,but my "ambigious nit sensor" goes off and I start wondering ....
Is Lead solder Hazardous?
Is the Lead in Brass Hazardous?
Is the gallium arsenide in the GASFET RF amplifiers hazardous?
So I write the following:
Unreasonable rocket will not be using any environmentally hazardous substance, we are only using benign non-toxic propellants . The non- consumable portions of the vehicle will be constructed with aluminum,copper, stainless steel and normal composite structures. The only components of vehicle that might contain nominally hazardous materials are the trace elements in the electronic components and lead containing solders that are part of these assemblies. The commercial components will all be RHOS compliant lead free, but the non commercial components assembled for this effort will use lead solder for reliability purposes.
What I finally put in the application is:
Unreasonable rocket is not using any hazardous consumables.
What I finally put in the application is:
Unreasonable rocket is not using any hazardous consumables.
1 comment:
Regarding material safety designations - refer to any MSDS that you may get from the manufacturer of such materials. Also, LOX and all fuels, not to mention the combustion gases produced by the LOX and a fuel are all hazardous. Is lead safe? Depends.
All of your questions are "depends" - as such you must take context, control, exposure, and liability to exposure to such materials.
Is lead a toxic chemical? Yes, but in such a low amount that you will be using and in the context in which you are using it, and WHO will use it or be exposed to it makes it a non-toxic chemical. Now, if you were to make pottery with lead - the exposure will be direct - it will be a lot of it, and it will expose anyone touching it - therefore, in such a case it would be toxic.
Get my drift?
What you tell the FAA depends on what context they will look at it with.
A rocket that will be manned by yourself, and not some general member of the public is not a danager, while if you were to hire some person or ask some person who walks by to pilot it - then it would be danagerous.
Simple.
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