I am in the midst of the LEUP process and just received a call from my
contact about the variance for attached garages. One of the stipulations is
that the "initators" ie, igniters, are in a separate magazine. I cannot
believe that you all have two magazines so I assume that there is some
ruling on the igniters.
Please let me know how you have handled this.
Western New York Sailplane and Electric Flyers
Believe it. As my inspector said "you can't store the explosives with
the thing that makes it go boom". No joke. You either need a Type 2
detonator box or a Type 4 indoor magazine. I made an ammo box with two
hasps (not hooded because my garage qualifies as a "secure" location).
I could have gotten by with one hasp. I lined it with wood, so it is a
Type 4. If I'm ever challenged I'll replace the wood with sheet
aluminum and it becomes a Type 2 Detonator box.
As stupid as the rest of the LEUP process was, the ignitor box almost
put me over the edge. If/when we manage to get APCP off the explosives
list we still have Black Powder and Electric Matches to worry about. A
pre-assembled ejection charge sure sounds like a PAD, but a pound of BP
and a dozen ematches isn't.
Thomas Koszuta wrote:
So you have to open any reloads you get, pull out the ignitor and put it
into another box? Aren't the ignitors basicly the same as MR ignitors?
I can deal with taking the igniters out, but another box?
Even if we win on the definition of APCP we still have to deal with
electric matches and black powder. Ask your local fire department about
storage of black powder, you may be surprised by their answer. Even
though my federal permit allows me to store up to 50 lbs, local code
limits me to 2lbs in a magazine or 1lbs without. Granted, that's close
to a lifetime supply for some but still a consideration. Assembled
ejection charges should be considered PADs, but I think it is safer to
store them separately.
Do you have local storage? Are you allowed to store igniters in the same
mag as the reloads and BP? If not, what kind of mag do you have the
igniters in? Do Tripoli or NAR have any advice or regs to cite for variance
on the explosive/detonator thing as it applies to propellant/igniter?
It's all about what your agent wants and what your local fire marshall
requires. I can't think of two people for whom the requirements have
been the same, even locally. I won't say anything about what I do for
fear that some helpful individual will toss a monkey wrench in my
The process is "fubar'd".
I have been dealing with snarky people all day, so if I have been snarky
as well I apologize.
I agree that there is a good deal of subjectiveness in the process, however,
when given a hard reference like Ruling 2002-3, the local joe has to comply
Anybody have a similar doc for the igniter thing?
I am going through the same process here in Rochester.
The fastest way to a permit is to "Yes sir, thank you sir" to whatever
the agent wants. Ask him for advice, suggest a small lockable metal
tool box to store the miniscule amount of igniters you will need, and
maybe he'll say fine and you are all set. Arguing or resisting will
just set the bar higher I am afraid.
Also for the other comments, if anyone thinks that APCP is coming off
the explosive list anytime soon I think they are setting themselves up
for major dissappointment (IMHO).
I think in this case the agent is wrong, but that may not matter.
I believe that it is true that high explosives and detonators have to
be stored in separate magazines, but rocket motors and igniters are
both classified as low explosives and low explosives can be stored
together in a type 4 mag. I will dig more on this and see what the
Nevertheless, the shortest path to a permit may be "Yes sir, thank you
sir, may I have more advice please" with regards to your agent.
27 CFR 555.213(b) has the restriction on detonators:
(b) Detonators are not to be stored in the same magazine with other
explosive materials, except under the following circumstances:
(1) In a type 4 magazine, detonators that will not mass detonate may
be stored with electric squibs, safety fuse, igniters, and igniter cord.
(2) In a type 1 or type 2 magazine, detonators may be stored with
delay devices and any of the items listed in paragraph (b)(1) of this
27 CFR 555.202 describes the different classes of explosives:
For purposes of this part, there are three classes of explosive
materials. These classes, together with the description of explosive
materials comprising each class, are as follows:
(a) High explosives. Explosive materials which can be caused to
detonate by means of a blasting cap when unconfined, (for example,
dynamite, flash powders, and bulk salutes). See also Sec. 555.201(e).
(b) Low explosives. Explosive materials which can be caused to
deflagrate when confined (for example, black powder, safety fuses,
igniters, igniter cords, fuse lighters, and ``display fireworks''
classified as UN0333, UN0334, or UN0335 by the U.S. Department of
Transportation regulations at 49 CFR 172.101, except for bulk salutes).
(c) Blasting agents. (For example, ammonium nitrate-fuel oil and
certain water-gels (see also Sec. 555.11).
Note that igniters are given as an example of low explosives.
The definition for detonator is:
Any device containing a detonating charge that is used
for initiating detonation in an explosive. The term includes, but is not
limited to, electric blasting caps of instantaneous and delay types,
blasting caps for use with safety fuses, detonating-cord delay
connectors, and nonelectric instantaneous and delay blasting caps.
There is no definition given for igniters. Which would be useful as the
term is somewhat ambiguous. There are igniters in turbojet engines which
are obviously not explosive and I seem to recall that the British, with
their somewhat different approach to some terms, refer to spark plugs as
David W. Schultz
I hate to say this, but since it involves a variance it doesn't matter.
The ATF is not obligated to grant variances. 2002-3 outlines the
minimum requirements. From what I've heard, the requirement for
separate storage of igniters is pretty common for attached garage
variances. It's silly but if you work with your inspector (and DC if
necessary) you can find a path of least resistance. A Type 2 detonator
box isn't hard to construct.
This prohibition on initiators/igniters in the same magazine is stupid.
The last few times I assisted with a fireworks show, the vast majority
of the product (mostly from China, alas) was delivered from the factory
with the electric match already installed in the BP lift charge with no
simple way to remove it. The shells ranged in size from 3" to 6". So
obviously almost every display firework shell in the US is not only
stored in a magazine with igniters, the igniter is in fact already
It's the government, it doesn't have to make sense.
David W. Schultz
Do you have a LEUP with storage? How did you get around it for your HPR
motor storage? Is there some ruling like 2002-3? Did you get a separate
box? What kind? How much?
BTW, I agree that it is ridiculous to take a sealed motor reload kit out of
the cardboard box it was shipped in, cut open the package, and put it into a
60 pound steel box with two hasps and potentially put the ignitor into
another 60 pound steel box with two hasps, but that does not help me with
Yes and no. There is no longer any such thing as the User of Low
Explosives Permit (sometimes called a "LEUP"). There is only the User of
Explosives Permit which lets you use low explosives, high explosives,
blasting agents, and display fireworks. This change occured last July
but the ATF as usual will probably be a while updating their paperwork.
I do not have a separate box and I have not removed igniters from
packages. I have nothing in my magazine right now but I think that the
last reload I had in there (Aerotech K550) had no igniter with it.
Actually, they will (I think) let you use a Type 2 detonator box which
requires a single unhooded padlock.
However, if fireworks can be stored with e-matches installed, a rocket
motor reload kit can surely be stored along with its igniter in the same
David W. Schultz
The permit app I filled out had a check box for low explosives user. The
paperwork may be behind, but that is what I checked.
Did the inspector cite this as a condition for storage?
There has got to be a precedence for the HPR motors, that are stored by
manufactures and distributors with igniters in the packs, to be stored by
individuals the same way.
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