2004-07-13
Here is the National Firearms Association Guide to the Current Regulations
New! Sept 2004: Department of Natural Resources Update
The
federal Department of Natural Resources is reviewing proposals with
regard to smokeless powder, black powder and reloading of ammunition.
The
civil servants in this department have asked for input from firearms
owners, ammunition re-loaders and other interested parties.
In
bold in this paper are the ideas which have come forward though the
Department of Natural Resources which they have requested comments from
individuals.
The National Firearms Association has provided some information following each of these proposals.
We encourage you to write to:
Juri Kasemets
Manager, Eastern Division
Explosives Regulatory Division
Natural Resources Canada1505 Barrington Street, Halifax, Nova Scotia, B3J 3K5
Tel: (902)426-9486
E-mail: jkasemet@nrcan.gc.ca
We would ask that you also send a copy of your message to the National Firearms Association (
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This email address is being protected from spam bots, you need
Javascript enabled to view it) and the Canadian Shooting Sports
Association along with your Member of Parliament.
The
National Firearms Association suggest that one of the goals the
Department of Natural Resources should be seeking is greater
consultation with industry experts and firearm groups -- this would
duplicate the process that they use in other areas.
Your letters adding this suggestion would be helpful.
Here is the text of the letter we received from the Department of Natural Resources on this topic.
"Thank
you for your email expressing your concerns over proposed changes to
regulations under the Explosives Act relating to handloading of
ammunition. The proposals that you refer to were released to start
the consultation process. A newsletter has recently helped spread the
information to the reloading community.
There is no connection between these proposals and the recently passed Public Safety Act
(Bill C-7; formerly C-42). Proposals for that Act were aimed at
import, export and in-transit controls over "inexplosive ammunition
components". These proposals were withdrawn due to objections from the
firearms community.
The proposed regulations on handloading relate mainly to safety, not security. Addressing each of the proposals:
- Handloading
in detached dwelling only. The accidental ignition of 5 kilograms (kg)
of black or smokeless powder can cause a fireball several metres
across. This would undoubtedly initiate a rapid and intense fire in a
normal room. We do not believe that residents in a multi-unit dwelling
should be subject to the risk.
- No
more than 5 kg of propellant to be stored within a dwelling.
According to handloading tables this is sufficient for 1500 (shotgun)
to 20,000 (pistol) loads. This amount seems adequate.
- No
handloading within 15 metres of a neighbouring dwelling. Again, this
proposed change relates to protecting neighbouring properties from the
risks and hazards associated with ammunition loading activities.
- All
propellants to be given a United Nations designation. There is nothing
new here. All explosives made in or imported into Canada must be
authorized and classified under the UN system.
"The Explosives Act
prohibits the manufacture of explosives (including ammunition) anywhere
except in a licensed factory - unless exempted by regulations. We have
for many years made regulations to exempt handloaders from this
prohibition and, thus, avoid the expense of acquiring a factory
licence.
"We are looking for constructive
feedback on these proposals. Consultation with stakeholders is part
of the regulatory process. When the proposals are fully developed they
will be posted on our website (www.nrcan.gc.ca/mms/explosif/index.htm).
Please tell us what you think."
Here are the National Firearms Association's
COMMENTS ON EXPLOSIVES ACT PROPOSALS
1. Handloading
in detached dwelling only. The accidental ignition of 5 kilograms of
black or smokeless powder can cause a fireball several metres across.
This would undoubtedly initiate a rapid and intense fire in a normal
room... We do not believe that residents in a multi-unit dwelling should
be subject to the risk.
Comment:
Once again, the government is equating smokeless powder (classed as a
flammable solid for transportation purposes, including transportation
by air) and black powder (classed as a low explosive). It is very
inaccurate to try to claim that those two have any great degree of
equality.
The word "undoubtedly" indicates that no testing of this theory has been done.
In
real-world terms, there is virtually no way that anyone could ignite "5
kilograms" of smokeless powder, and get "a fireball several metres
across. If a 1-pound can or cardboard canister of smokeless powder is
ignited:
(a) No
explosion takes place, because smokeless powder does not "explode"
unless contained in a very strong container, such as a closed steel
pipe or a firearm chamber. It deflagrates, decomposing into hot gas.
Only if there is nowhere for that hot gas to go can one get anything
remotely resembling an explosion.
(b) The deflagration takes place only at the surface of the smokeless powder, which severely limits the rate at which the hot gases are produced.
(c) The deflagration does not
propagate to other 1-pound containers of smokeless powder that are
physically touching the deflagrating can or cardboard canister.
The
idea that "a fireball several metres across" can be produced using
smokeless powder kept in either normal containers or a reloading powder
measure is nonsense, and will bring the Department of Natural Resources
-- Explosives Branch into disrepute if published.
Black
powder, on the other hand, is a low explosive. If ignited, it burns,
turning a mixture of three chemicals into hot gases at a very much
faster rate than anything that can happen with smokeless powder. The
rate of burning can be accelerated by containing the hot gases to
increase the pressure, but when burned in the open, or in a normal
metal can or cardboard canister, there is no explosion. There is just
a "Whuff!!" As the black powder burns, with great rapidity, but without
explosive force.
Black powder, today,
is used almost exclusively for muzzle-loading firearms. It is
therefore kept and stored in metal cans, and transported in metal
cans. Such a can is never opened in any place but a shooting range or
in the field for hunting, where the black powder is used for loading
muzzle-loading firearms. There, it may be transferred into a powder
horn or a reloading flask. The Canada Firearms Safety Course covers
black powder and safe handling proceedures.
2. No
more than 5 kg of propellant to be stored within a dwelling. According
to handloading tables this is sufficient for 1500 (shotgun) to 20,000
(pistol) loads. This amount seems adequate.
If
handloaders loaded only one type of cartridge, this claim might have a
grain of validity. However having accurate information from individual
reloaders and industry experts can help make sure that e department is
more aware of the requirements of reloaders. .
A
handloader usually loads a variety of ammunition -- some pistol
cartridges, some rifle cartridges, and some shotgun cartridges. A
single type of smokeless powder usually cannot be used for all the
pistol cartridges, or all of the rifle cartridges, or
all of the shotgun cartridges. The deflagration rate of the smokeless
powder used for one calibre of rifle cartridge, for example, renders it
quite unsuitable for another calibre of rifle cartridge.
In
reloading ammunition, it is very necessary to use the right type of
smokeless powder for each type of cartridge being reloaded. The
Department of Natural Resources -- Explosive's Branch's simplistic
position, as stated above, makes it very obvious that government is
attempting to regulate an activity it knows startlingly little about,
by proposing regulations based on fallacies.
3. No
handloading within 15 metres of a neighbouring dwelling. Again, this
proposed change relates to protecting neighbouring properties from the
risks and hazards associated with ammunition reloading activities.
This
proposal is apparently intended to prevent ammunition reloading
anywhere within any urban or town setting. The slightest bit of
thought will show that there is rarely a 15-metre gap between any
normal house and the house next door. This is not a "safety" measure,
it is an attempt at disguised prohibition of nearly all reloading
activities. As such, it will be fought -- by demanding that the
government produce records of any and all incidents
where any reloading activity has caused damage to any house other than
the house where the reloading activity was taking place.
In
order to get maximum research data from such a search of real data, a
demand will also be made that the government also publish records of
all reloading incidents that caused damage to the house in which the
reloading activity in which the reloading activity was taking place.
The
National Firearms Association is quite confident that such records will
prove that the government is trying to regulate -- with rather savage
prohibitions -- matters that have not historically been a problem even
with little or no regulation. This is, apparently, a set of proposals
not based on knowledge of what is required.
4. All
propellants to be given a United Nations designation. There is nothing
new here. All explosives made in or imported into Canada must be
authorized and classified under the UN system.
If
there is "nothing new here," why is this proposal being made? What is
meant by "authorized...under the UN system"? Is this yet another
giveaway of Canadian sovereignty, for no discernable purpose?
Great
reference material to utilize in your replies could include Hatcher's
Notebook, by Major General Julian S. Hatcher U.S.A. Ret. ISBN Number:
0-8117-0795-4
The
National Firearms Association asserts that rather than another level of
increased regulation -- that what is really needed is an educational
campaign involving industry, government, and the National Firearms
Association and other related stakeholders.
Perhaps,
the Department of Natural Resources --Explosives Branch could help
establish a new standard where firearm owners, firearm groups,
industry, and the federal department could work together.
The National Firearms Association would support such a move. {mosauthorxtd noshow}