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.
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 ejecti> I am in the midst of the LEUP process and just received a call from my
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?
If you can't store the igniter with the motor then why are they shipped that way in the same package? I am talking about 38mm and smaller motors.
Les.
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 installed!
It's the government, it doesn't have to make sense.
I gotta ask...do you think it's a wise idea to ship big fireworks with a match already installed? It's like shipping su motors with a match/igniter installed.
Ted Novak TRA#5512 IEAS#75
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 the inspector.Tom K.
They make this #@%! up as they go. They told me my ignitors were unregulated and didn't have to be in the magazine or on my inventory. But they cited me for not having records for easy access motors I bought a decade ago, nad for not having a current permit even though it took them 5 months to issue a renewal.
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 package.
I sure hope you cited them back for taking longer then the required 45 days for your renewal.
Hi David.
Didn't a major motor manufacture tell us here about a year ago if the igniter was part of a motor package it was exempt from the separate magazine requirement. But if it was separate, they were telling us to put them in a separate box ?
The Safe Explosives Act changed that to 90 days.
If they take longer than the statutory limit of 90 days, write to one of your congressman. Point out that the law ( 18 USC 843(c) ) _requires_ the ATF to act within 90 days. From personal experience I know that this stirs them up quite nicely. :-)
My memory isn't that good.
But there is no law or regulation that requires igniters be stored separately under any circumstances. They are making it up as an additional condition on the attached garage variance.
You don't want to open reload kits, particularly white lightning until ready to use the motor. The grains oxidize faster once opened.
This is crazy. You can buy a G reload with no certification of any sort necessary, store the igniter with the reload, and there is absolutely nothing wrong. Bump it up to a regulated motor with the same composition, and the SAME PHYSICAL IGNITER, and suddenly you need to store the igniter differently???
Is this the makings of lawsuit, part deux???
David Erbas-White
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.
Tom K
They treat igniters as detonators (I know, they don't initiation a detonation) and 555.210 says
I tried to push the definition of a detonator... in response I was asked "do you want this permit or not?".
If/when we win the ruling on APCP we still have to contend with electric matches and black powder.
What explosives?
How did the agent know you had the EA motors? Did you show them the easy access motors? Surely you didn't just reach under the table and hand agent man a J-350 and ask "how do I store these", or have them in the magazine?
What permit?
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.
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