Wanted to start a new thread about the indoor storage issue. I found this unit....http://www.merlinmissiles.com/explosives_magazine.html
Do you think it would work? Certainly a cheaper alternative to the one I mentioned in the other thread!
wrtiii
January 26th, 2006, 06:00 PM
Presumably the company selling these can read the regulations and know whether this complies. However, you should be aware that you are meeting at most the bare minimum requirements here. Don't forget that you are subject to all the other regulations concerning distance from inhabited building, etc. PLUS any state or local regulations.
Remember that you can not store Ematch (classed as a detonator) and your fireworks in the same magazine.
You can look at the regulations here...
http://www.info-central.org/regulatory/orangebook/
Don F
January 26th, 2006, 06:06 PM
shoot thats no bigger than my 20mm ammo box
wonder if I put hoods on it if it would work ;)
ap0352
January 26th, 2006, 06:40 PM
I too was wondering about the hoods. The book dosen't mention hoods if mortise locks are used. By the way, what is a mortise lock?
I also was under the impression that the magazine had to have a hinged door? After reading the book, it dosen't really seem to make it clear. I assume that the magazine I mentioned is "up-to-par" being that they claim it "meets or exceeds current BATF regulations". I also assume there could be legal issues if they claim it meets regs. but actually doesn't....
If I do purchase this mag., I will be using it as an indoor storage unit specifically for e-matches, if approved.....
Marty
January 26th, 2006, 06:43 PM
Remember that you can not store Ematch (classed as a detonator) and your fireworks in the same magazine.
You can look at the regulations here...
http://www.info-central.org/regulatory/orangebook/
Help me here,
Where does it say that igniters are classified as detonators? I cannot find it in my Orange Book or on the link you provide.
From the BOOK-
"Detonator. 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."
Just so that we are on the same page here, they are igniters, not e-matches nor are they squibs. They deflagrate, they do not detonate, nor will they cause an explosive to detonate. There is no comparing an igniter to a detonator or even a REAL squib, which is actually a type of detonator.
Don F
January 26th, 2006, 06:52 PM
Just so that we are on the same page here, they are igniters, not e-matches nor are they squibs. They deflagrate, they do not detonate, nor will they cause an explosive to detonate. There is no comparing an igniter to a detonator or even a REAL squib, which is actually a type of detonator.
Amen
laws are all about definitions
Marty
January 26th, 2006, 06:59 PM
Amen
laws are all about definitions
True Don,
I'll admit I'm as bad as anybody else in using the e-match and squib slang terms. :redface:
That's how is was initially taught and the habit is very hard to break :( but I'm trying.:)
ap0352
January 26th, 2006, 07:03 PM
I should probably know this but can I use a type 2 or 3 magazine instead of a type 4?
Marty
January 26th, 2006, 07:18 PM
I should probably know this but can I use a type 2 or 3 magazine instead of a type 4?
Yes, but be sure you know the limitations and exceptions for any type of magazine you use in accordance with the regs.as outlined in 27CFR55 and all of its subparts and appendices.... AKA-Orange Book, which is free for the asking at the ATF website, or online review at http://www.info-central.org/regulatory/orangebook/
Don F
January 26th, 2006, 07:19 PM
absolutely
a type 2 is more secure than a type 4
the type 2 has 1.5 to 2" of hard wood on the inside
A septic tank with a approved door and locks would work as well or a tornado shelter (steel or concrete)
Dan
January 26th, 2006, 07:29 PM
Marty, I agree 100%. I find NOTHING that states anything about fireworks "ignitors" yes, blasting caps and detonators and det. cord. all must be stored in their own comparments. Hence the reason MOST type 2 magazines have the small box attached to the larger magazine.
But I have seen nowhere that fireworks "ignitors" can't be stored in the same magazine as fireworks.
Dan
Chiprivrat
January 26th, 2006, 08:08 PM
absolutely
a type 2 is more secure than a type 4
the type 2 has 1.5 to 2" of hard wood on the inside
A septic tank with a approved door and locks would work as well or a tornado shelter (steel or concrete)
Basically type 1 and 2 magazines are bullet-proof and able to store high explosives. Type 4 is not bullet-proof and for low explosives.
Don, I think your ammo can would work if you anchor it to a solid object and make it sparkproof inside. Then you could store a 5" shell! :D
As far as storing E-match in a magazine with fireworks there is nothing wrong with the legality of doing it. I would feel better if they were stored in a separate fireproof container within the mag like an aluminum spark proof box.
Chiprivrat
wrtiii
January 27th, 2006, 05:25 AM
Maybe people here would be happier if I phrased this along the lines of "Our local ATF inspector says that Ematch cannot be stored in the same magazine as explosives. Other licensed operators in other regions report that their ATF inspectors enforce the same interpretation." Argue this point with your own ATF inspector as much as you wish.
lamrith
January 27th, 2006, 05:42 AM
shoot thats no bigger than my 20mm ammo box
wonder if I put hoods on it if it would work ;)
That is what I have been wondering... THat or a steel fireproof safe you can buy all over?? those would have a built in combo lock normally, not sure how that may be viewed by ATF.. You would have a very valid point that the lock was shrouded as it is inside the case!!
Don F
January 27th, 2006, 05:58 AM
I do not doubt what your saying.
I can see some serious problems in the future with prematched shells.
It seems each state and each agent has a slightly different determination of what they view as legal.
Personally these judgement calls and lack of definate regulations create confussion. There have been cases in the past were an agent approved a certain way of doing things, after that agent was transfered /retired/quit the agent replacing them has sighted the magazine owner for violations. Such things can happen easily depending on the agents interpretation.
Then of course local and state laws come into play adding to the confussion.
a thought for starage of ignitors might well be the 20MM ammo box eqipped with hoods locks and welded or bolted to the out side of the mag .
Its my understanding as far as the DOT is concerned ignitors are still 1.4 though this does noy mean they can be sold as consumer fireworks its simply the dot designation. There seems to be some question (depending on the local agents) whether or not ignitors must be stored in a magazine or simply in a secure location. It would be Nice for all of us if there were distinct black and white regs on somethings rather than relying on the judgement or interpretation of various agents which are subject to change at will.
this is just my opinion.
ap0352
January 27th, 2006, 06:50 AM
Can someone explain what a mortise lock is..... What about the top being hinged.....Read my post toward the beginning...
wrtiii
January 27th, 2006, 07:10 AM
From Schlage:
Mortise locks are generally considered the heaviest duty products in the marketplace. They are typically used in area of high traffic or heavy commercial usage, where greater security is required. A mortise lock is installed in a mortised pocket in the door, with the housing of the lock contained in the door. The cylinder is screwed through the skin of the door directly into the metal lock case, with only the cylinder head and spin ring projecting from the face of the door. The lock case may contain a dead bolt as well as the normal dead latch for added strength and security.
Compare to padlocks with hasps of specified size and hoods (so you can't apply a hacksaw blade to the hasp).
I know people who report success with getting gun cabinets with 3 point mortise locks approved as Type 4 indoor magazines. Buy it at Kmart or Wal-Mart, paint it with epoxy paint, and line the inside with Masonite. Note that these are not gun safes; I don't think the combination locks meet the requirements.
Before you buy the small mag. with the removable lid, ask the manufacturer whether they can refer you to someone who has successfully gotten one certified by the ATF.
ap0352
January 27th, 2006, 07:54 AM
I spoke with the rep at merlin's missile and he said they have never had a problem with anyone "not" getting approved with one of these magazines....
I still wonder if I can get someone locally to build one for me for a better price. 14"x11"x22" is quite small and I would prefer one about 3'x3'x3'......Hmmmm....
Chiprivrat
January 27th, 2006, 08:20 AM
Its my understanding as far as the DOT is concerned ignitors are still 1.4 though this does noy mean they can be sold as consumer fireworks its simply the dot designation. There seems to be some question (depending on the local agents) whether or not ignitors must be stored in a magazine or simply in a secure location. It would be Nice for all of us if there were distinct black and white regs on somethings rather than relying on the judgement or interpretation of various agents which are subject to change at will.
this is just my opinion.
Don you are correct, they are classified DOT 1.4s and all this B.S. about agent interpretation of the law does a disservice to everyone. I have seen these things being stored in warehouses, metal cabinets in offices, in magazines with fireworks and separate attached magazines. My inspector wants them in the magazine along with the fireworks. I could bolt that little magazine to the wall in my shop and it would be an approved type 4 for storage of up to 50lbs of low explosive or ignitors/e-match. Move it to another inspectors area and it may be a different story.
Everyone has to understand this is the way the government operates and why they write the laws this way. They want to ticket you and then have you hire a lawyer to prove their vague law correct or incorrect to your specific circumstance. Once that is complete then there is a legal precedent and either you win or lose (actually always lose financially). Either way the lawyers win and that is why this country is ruled by the trial lawyer and why they contribute so much money to government officials. :puke:
I have been on a little rant here lately, I think Marty got me going on that.
Chiprivrat
Chiprivrat
January 27th, 2006, 08:29 AM
I spoke with the rep at merlin's missile and he said they have never had a problem with anyone "not" getting approved with one of these magazines....
I still wonder if I can get someone locally to build one for me for a better price. 14"x11"x22" is quite small and I would prefer one about 3'x3'x3'......Hmmmm....
You could build one easily although their price seemed reasonable. I would call or email your ATF inspector and ask for a determination letter based on what you are trying to do. It makes no sense to do something and then have them tell you later they don’t like it. Seems if you ask up front and get the letter of determination things (the relationship) are much better. I think it is a "control" issue.
Chiprivrat
ap0352
January 27th, 2006, 08:35 AM
Can you clarify the determination letter...
Thanks
Chiprivrat
January 27th, 2006, 08:42 AM
Can you clarify the determination letter...
Thanks
Basically it would just be a letter from your local ATF jurisdiction stating that what you have presented to them is approved based on the presentation details, subject to final inspection. (You would have to make a detailed presentation) Example: I wanted to put in a type II mag in a location I was unsure of its legality so I drew up a presentation and sent it to the local inspector for approval BEFORE doing it, it is still in process but I should have something in a couple weeks. Oh, and I have found presentation is EVERYTHING!
Almost every government entity has this process for pre-approval of things that are not clear cut in the law.
Chiprivrat
Marty
January 27th, 2006, 09:23 AM
Maybe people here would be happier if I phrased this along the lines of "Our local ATF inspector says that Ematch cannot be stored in the same magazine as explosives. Other licensed operators in other regions report that their ATF inspectors enforce the same interpretation." Argue this point with your own ATF inspector as much as you wish.
I am not arguing about the storage with product safety issue at all, that is common sense. Irregardless of what is in the regs.or not, we store them separate unless the product is manufactured with the igniter installed.
My original question was about them being "Classified as Detonators" and the reference you provided did not support that claim.
The problem here is that licensees and permitees allow the missinterpretations of the inspectors to go unchallenged. Why? I dunno, maybe fear of rebuttal, blind faith or whatever. Really it is probably due to the fact that they simply don't know the regs.well enough to challenge the inspector.
Do I know it all? Of course not. Neither do the inspectors, they are human also. When I feel something isn't right, I dig thru the regs.and make my case or I shut up if the regs.support their interpretation. If I challenge an interpretation and a common ground can't be reached with the inspector, it is simply submitted to the regional office for a final say, it's not a tooth & nail fight.
I did challenge this issue with the inspectors, and the regional office supported my interpretation.
For now.....
EDIT:This issue being, calling igniters detonators. The storage issue never came up during the inspection.
Chiprivrat
January 27th, 2006, 11:26 AM
The problem here is that licensees and permitees allow the missinterpretations of the inspectors to go unchallenged. Why? I dunno, maybe fear of rebuttal, blind faith or whatever. Really it is probably due to the fact that they simply don't know the regs.well enough to challenge the inspector.
Do I know it all? Of course not. Neither do the inspectors, they are human also. When I feel something isn't right, I dig thru the regs.and make my case or I shut up if the regs.support their interpretation. If I challenge an interpretation and a common ground can't be reached with the inspector, it is simply submitted to the regional office for a final say, it's not a tooth & nail fight.
Marty, I think you hit it right on the head and a little clearer than my previous post. Most of the laws are written so ambiguously that no one could tell you exactly what they mean in every given case. There is way too much interpretation built in which can be good or bad because everyone looks at things in a different way (see definition of “judge”). The point is to know the regulation to the best of your ability and apply that to your reasoning when making an argument on your point of view when you think you are being steered in the wrong direction.
I don’t agree that my igniters should be stored with the fireworks in my magazine. I would rather have them in a locked steel cabinet in my locked shop but the inspector said they needed to be in the magazine WITH the fireworks so I did not argue too much. I have the opinion that they are a lot more worried about theft than the possible explosion of a magazine where given my location and circumstances I am more worried about the latter. Needless to say my next magazine will have an attached “cap box” to store the igniters that way I will get some sleep on those stormy nights. :eek:
Chiprivrat
Marty
January 27th, 2006, 12:14 PM
Needless to say my next magazine will have an attached “cap box” to store the igniters that way I will get some sleep on those stormy nights. :eek:
Chiprivrat
Just my hunch, but putting the cap box on now will have you in compliance when, not if, it IS written into the regs. The issue is getting to much attention for them to ignore on the next round of changes. :rolleyes: