Jerry Irvine wrote: > In article , > snipped-for-privacy@aol.com (RayDunakin) wrote: >
Air bags are NOT exempted as propellant actuated devices. They fall into the "special explosive device" category in 27 CFR 555.32. This was in one of the BATFE Explosives newsletters.
The only cartridges for nail guns that I found look very much like regular 22 caliber ammunition except that they don't have a bullet. Perhaps they are sliding through the exemption for small arms ammunition and components.
RayDunakin wrote: > Jerry wrote: > and igniters) per 27 CFR 555.141-a-8. >
Duh. Show me where it specifically exempts reloads/cartridges and/or igniters. It talks about Propellent Actuated Devices, but igniters are not PADs. Reloads are part of the PAD "system" and could be considered exempt that way, but unless there is more precise language exempting them, you can bet your bottom dollar that the ATF will "interpret" that gray area to suit their agenda.
It would be really helpful if we could find:
Some other examples of PADs which have separate reloads that are exempt.
A manufacturer of such, who could give us some insight without having a vested interest in the issue of rocket motors as PADs.
Once again, you have merely quoted the definition of a PAD. You have NOT shown anything which states that individual PAD components, propellent loads, or igniters are exempt.
The definition you keep quoting does not address the issue of propellent loads for PADs. Nor does it address igniters, which are not even specifically intended for use in PADs.
There may be some precedent for exempting these things (in fact, I'm counting on it). However, unless there is some specific language that makes it clear that propellent loads for PADs, and/or igniters, are exempt, then it is a gray area which the ATF will try to interpret to suit their agenda.
Yes, any PAD. But an ignitor is definitely not a Propellent Actuated Device. Reloads or cartridges are not complete propellent actuated devices, they are merely the propellent load that goes into those devices.
Now, you and I both know that cartridges are exempt despite the fact that they are not PADs, so it's logical to assume that reload kits are also exempt. But so far, I haven't seen the regs which make either cartridges OR reloads exempt. Until I do, I'm forced to conclude that these materials are in a regulatory gray area.
And still you insist on repeating the same quote over and over, without addressing the real issue. An igniter is NOT a "tool". It is NOT a "special mechanized device". It is NOT a "gas generator system". So HOW can you say that igniters are PADs?
I wrote:
Jerry gave the following one-word pseudo reply:
So you're saying that reload kits and cartridges are "propellent actuated devices"? What's a nailgun then, if the cartridge is a PAD? How is a cartridge a "device"? Or a "tool"? Looks to me like a cartridge is just a tube full of propellent, that goes INTO a Propellent Actuated Device. Same with reloads.
Quit getting huffy and just discuss this logically, please. It's not like I'm trying to prove reloads and cartridges aren't exempt. Obviously cartridges ARE exempt, because I can go into Home Depot and buy hundreds of them without a permit. Logically, the same should be true of reload kits. I just want to know specifically what regulations exempt them, and how.
As I see it, you have three ways to respond correctly:
Show me HOW igniters, cartridges and reloads are legally considered PADs, despite the fact that they are neither devices nor tools.
Show me the regs that exempt igniters, cartridges and reloads as _components_ of PADs.
Admit that although they are clearly exempt, you don't know what regulations exempt them.
If there's some fourth answer I'm unaware of, spell it out. Don't just give some one-word answer that doesn't explain anything.
How can you deny the obvious, that you are a moron.
tool ( P ) Pronunciation Key (tl) n.
Something used in the performance of an operation; an instrument: ³Modern democracies have the fiscal and monetary tools... to end chronic slumps and galloping inflations² (Paul A. Samuelson).
Synonyms: tool, instrument, implement, utensil, appliance These nouns refer to devices used in the performance of work. Tool applies broadly to a device that facilitates work;
Hence, any instrument of use or service.
A weapon. [Obs.]
n 1: an implement used in the practice of a vocation 2: the means whereby something is accomplished
mo·ron ( P ) Pronunciation Key (môrn, mr-) n.
mo·ronic (m-rnk, mô-) adj. mo·roni·cal·ly adv. moronism or mo·roni·ty (m-rn-t, mô-) n.
A stupid person; a dolt.
Psychology. A person of mild mental retardation
\Mo"ron\, n. (Pedagogy) A person whose intellectual development proceeds normally up to about the eighth year of age and is then arrested so that there is little or no further development.
n : a person of subnormal intelligence [syn: idiot, imbecile, cretin, changeling, half-wit, retard]
What's all the fuss about, guys? The igniter is a system component of a specialized gas generator system: it's a functional _component_ of the exempt device.
Only in the broadest sense would an igniter be considered a tool, in the same way that anthropologists call blades of grass "tools" when chimps use them to extract termites. But the law has it's own definitions which are rarely as broad as dictionary definitions -- and the ATF tends to define things even more narrowly when it suits them.
Furthermore, if igniters are exempt as PADs, why does the explosives law as written by Congress _specifically_ list igniters as regulated explosives?
Yes, in the same sense that a stick of dynamite is a "gas generator system" -- they both produce gas when ignited. If you're suggesting that ANY flammable or explosive material is exempt as a gas generating system simply because it produces gas when burned, I can guarantee that the ATF will not agree with your definition.
Cute, but you should try debating with facts, reason and logic rather than name-calling. Seriously, I don't see why you are getting so hostile about this.
I agree that one could look at it that way, but it's still not cut and dried. Most igniters aren't designed or intended specifically for gas generator systems or other PADs. You'd have a stronger point if you limited it to igniters made specifically for a specific PAD system, but that wouldn't include things like Daveyfires or Oxrals, which are generic igniters used for many non-exempt purposes.
Then there's the fact that Congress specifically listed igniters as a regulated explosive, when they created the law regulating explosives. Why would they do that if they were going to turn right around and say that all igniters are exempt?
With reloads (and cartridges), the "system component" argument is much stronger. In fact, I believe that is exactly how they are exempt. After all, what good is a PAD exemption if it only exempts the tool and not the propellent loads needed to use it? Reloads/cartridges are designed and constructed for one specific purpose, and that is to be used in a specific PAD system.
Jerry keeps saying that reloads and cartridges are PADs _themselves_, when clearly they are only components. Semantics, maybe, but you can bet that the ATF will argue the semantics of it in court. They did that already when they claimed that rocket motors are not "devices". So I believe we must be prepared to argue our case with precise language and precise cites to back it up.
I don't understand why Jerry thinks that is too much to ask for.
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